International Existing Building Code: Does it Apply to My Existing Building?

As I have spent time in existing buildings over the years, whether surveying a building for potential renovations, reviewing existing conditions or doing inspections, the concept of the building “meeting code” often comes up. Building owners, building maintenance staff, or anyone that is concerned with the operation or maintenance of a building wants to know if their building is up to code. Unfortunately, “meeting code” can mean several different things, and it is easy to lose track of which codes actually apply to an existing building. Does the International Building Code apply? Or is the International Existing Building Code? Or both?
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In this post, we’ll explore the various building and fire codes that could apply to your existing building. There are many other codes (e.g. electrical, elevator) that we won’t specifically address, but the general thought process for those is similar. All references will be to the 2021 ICC codes, but many states and local jurisdictions modify these requirements, so be sure to verify the specific requirements for your area.

Note: If your building is a one or two family dwelling or a townhouse, the International Residential Code (IRC) is likely the applicable code. The IBC and IEBC typically do not apply to such buildings.

Existing Building Scenario 1: Normal Operations

​If you have an existing, permitted, occupied building that is proceeding with normal operations (meaning there is no construction activity occurring and you are not changing the use or occupancy of the building from the original design), “meeting code” is fairly simple.

​IBC/IEBC Compliance

First, the International Building Code (IBC) and International Existing Building Code (IEBC) generally do not apply to your building. The application of both codes is limited to situations where some level of work is occurring to the building.

For example, IBC 102.3.2 states:

The legal occupancy of any building existing on the date of adoption of this code shall be permitted to continue without change, except as otherwise specifically provided in this code, the International Fire Code or International Property Maintenance Code, or as is deemed necessary by the building official for the general safety and welfare of the occupants and the public.

In other words, the IBC does not require any change to your building unless there is a specific requirement in the International Fire Code (IFC), International Property Maintenance Code (IPMC), or the code official determines there is a required change necessary because of a threat to public safety. We’ll get to the IFC and IPMC shortly, but the final point is an important one to note. The code language does give the Building Code Official the authority to require a change to your building if they deem it is necessary for safety reasons.

In my experience, this authority is typically reserved for use when there is a clear danger to occupant safety. As a hypothetical example: if your building has an exit stairway that does not have any handrails, even though it was permitted that way from the beginning, the code official could deem the lack of handrails a big enough safety risk that they require you to install them. Assuming your building does not have any blatant safety risks, though, it’s unlikely that the code official would use this language to force a change in your building.

Similar to IBC Section 102.3.2, the IEBC has the exact same language in Section 101.4. Additionally, the overall scoping language in IEBC 101.2 states that the provisions of the IEBC apply to the “repair, alteration, change of occupancy, addition to and relocation of existing buildings.” So if you are not performing any of those actions on your building, the IEBC does not apply.

What about NFPA 101?

​​If you are in a jurisdiction that adopts NFPA 101, there are additional requirements you need to consider.
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Unlike the ICC, which separates the IBC and IEBC into two different codes, NFPA 101 applies to both new and existing buildings. For example, NFPA 101 Section 7.1.1 states “Means of egress for both new and existing buildings shall comply with this chapter.” NFPA 101 Chapters 7-11 all apply to both new and existing buildings, so you’ll need to review these chapters for specific existing building requirements that could apply to your situation. After Chapter 11, NFPA 101 contains occupancy-specific chapters that only apply if those occupancies are in your building. These chapters alternate between new and existing occupancies (for example, Chapter 12 applies to new assembly occupancies and Chapter 13 applies to existing assembly occupancies). So the requirements found in any of the applicable “existing” chapters in NFPA 101 would also apply to your building.

IFC Compliance

​Second, certain portions of the IFC will apply to your building. The application of the IFC is divided into two categories:

1. Construction and Design Provisions
2. Administrative, Operational and Maintenance Provisions

Let’s cover these one at a time:

​IFC Construction and Design Requirements

Per IFC Section 102.1, the construction and design provisions of the IFC “apply to:

1. Structures, facilities and conditions arising after the adoption of this code.
2. Existing structures, facilities and conditions not legally in existence at the time of adoption of this code.
3. Existing structures, facilities and conditions where required in Chapter 11.
4. Existing structures, facilities and conditions that, in the opinion of the fire code official, constitute a distinct hazard to life or property.”

In our Scenario 1 case, Items 1 and 2 would not apply since we are an existing, permitted building.
Items 3 and 4 would apply, though. Item 3 sends us to IFC Chapter 11, and, Item 4, similar to the IBC, gives the code official authority to enforce the IFC on existing buildings if they deem there to be a distinct hazard to life or property.
IFC Chapter 11 primarily focuses on fire safety and means of egress requirements. A few examples include:

• Standpipes in buildings with a floor higher than 50 feet
• Smoke Alarms in Group R and I occupancies
• Guards in the means of egress where the change in level is more than 30 inches
• Handrails on at least one side of stairways

​These requirements are fairly basic and typically are not difficult to achieve, but this would be a good section to thumb through to determine if they apply to your building.  IFC Section 1103.1 details which sections of Chapter 11 apply based on the use and occupancy classifications in your building.

​IFC Administrative, Operational and Maintenance Provisions

​Per IFC Section 102.2, the administrative, operational and maintenance provisions of the IFC “apply to:

1. Conditions and operations arising after the adoption of this code.
2. Existing conditions and operations.”

​In our Scenario 1 case, both of these items apply. This means you’ll need to review the IFC chapters that are relevant to the given system or component of your building under consideration to determine if there are any applicable requirements. For example, if you are working with a dry-cleaning facility, there are requirements in IFC Chapter 21 that would apply to how you operate the facility and equipment.

​What about NFPA 1?

If you are in a jurisdiction that adopts NFPA 1 in lieu of the IFC, you’ll have a little more work to determine what applies to your building.
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Similar to NFPA 101, NFPA 1 applies to both new and existing buildings and contains requirements for existing buildings throughout the code. You’ll need to review the chapters that are relevant to the given system or component of your building under consideration and then find the requirements for existing buildings located within those relevant chapters.

Existing Building Scenario 2: Changing an Existing Building

​If you are performing work on your building, there are additional code requirements beyond those described for Scenario 1.

​IEBC Compliance

The IEBC is your first stop for determining the applicable code requirements. IEBC Section 101.2 states that the provisions of the IEBC apply to the “repair, alteration, change of occupancy, addition to and relocation of existing buildings.” So you first want to review the definitions of each of these terms in IEBC Chapter 2 and determine which apply to the work you are performing in your building.

For repair work, the requirements of IEBC Chapter 4 apply. The general intent of this chapter is to maintain the existing level of code compliance in the building (at a minimum), though there are some specific additional requirements depending on the system or component undergoing repair.

For relocated building, the requirements of IEBC Chapter 14 apply.
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For the other IEBC work classifications: alterations, changes of occupancy and additions, there are three potential compliance paths:

• Prescriptive Compliance Method (IEBC Chapter 5)
• Work Area Compliance Method (IEBC Chapters 6 through 12)
• Performance Compliance Method (IEBC Chapter 13)

​Prescriptive Compliance Method

The prescriptive compliance method essentially requires the work being performed to comply with the requirements of the IBC, with a few exceptions involving situations where IBC compliance is unfeasible for an existing building.
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For many existing buildings, the requirements of the current edition of the IBC have progressed substantially since the building code that was in effect at the time of original construction, making any attempt to comply with the current IBC requirements difficult.

​Work Area Compliance Method

The work area compliance method is the most-commonly used compliance method in the IEBC and generally the most flexible from a technical requirement standpoint. This method applies varying requirements to the work area in the building based on the classification of work that is being performed. When the work area compliance method is used, the scope of work must comply with one or more of the applicable chapters:

• Alterations – Level 1 (Chapter 7)
• Alterations – Level 2 (Chapter 8)
• Alterations – Level 3 (Chapter 9)
• Change of Occupancy (Chapter 10)
• Additions (Chapter 11)
• Historic Buildings (Chapter 12)

For any building alteration, the requirements of Chapter 7 would apply. If the alteration includes “the addition or elimination of any door or window, the reconfiguration or extension of any system, or the installation of any additional equipment,” (IEBC Section 603.1), the requirements of Chapter 8 would also apply for a Level 2 alteration. If the work area exceeds 50% of the building, the requirements of Chapter 9 would also apply for Level 3 alteration.

Changes of occupancy and additions using the work area compliance method must comply with Chapters 10 and 11, respectively.
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Finally, if you have a historic building, be sure to reference IEBC Chapter 12 first, as it modifies several the requirements found in Chapters 7-11.

​Performance Compliance Method

The performance compliance method involves the evaluation of a variety of building systems and components (including height/area, compartmentation, vertical openings, means of egress, and fire protection systems). These systems are each assigned a score based on the evaluation criteria found in IEBC Chapter 13. These scores are then added to determine a total building score. If the score is high enough for the occupancy classifications involved, the work is deemed to be in compliance with the IEBC.
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The performance compliance method is a good option when one aspect of a proposed scope of work cannot conform to the other compliance methods, but the remainder of the building is generally compliant. For example, if an existing building work areas has excessive dead corridor lengths, compliance with the prescriptive compliance method or work area compliance method may be impossible. But the performance compliance method may be a viable option, assuming the building scores well in the other assessment areas.

​IBC Compliance

As described above in Scenario 1, compliance with the requirements of the IBC is only required when specifically referenced by the IEBC (or potentially in the IFC and IPMC).
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That said, if your work complies with the requirements of the current edition of the IBC adopted in your jurisdiction, this will inherently satisfy the requirements of the IEBC prescriptive compliance method.

​What about NFPA 101?

NFPA 101 Chapter 43 applies to any building rehabilitation work, including repairs, renovations, modifications, reconstruction, changes of use/occupancy and additions. Any of these actions would trigger a requirement to comply with NFPA 101 Chapter 43, which then brings in requirements to comply with other portions of NFPA 101, depending on the scope of work.
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Generally, NFPA 101 Chapter 43 requires compliance with all requirements found in the applicable existing occupancy chapter (Chapters 13,15,17,19, etc.) plus some additional requirements that vary based on the type of work being performed.

​IFC Compliance

​As described in Scenario 1, application of the IFC is divided into two categories:

1. Construction and Design Provisions
2. Administrative, Operational and Maintenance Provisions

Let’s cover these one at a time:

​IFC Construction and Design Requirements

Per IFC Section 102.1, the construction and design provisions of the IFC “apply to:

1. Structures, facilities and conditions arising after the adoption of this code.
2. Existing structures, facilities and conditions not legally in existence at the time of adoption of this code.
3. Existing structures, facilities and conditions where required in Chapter 11.
4. Existing structures, facilities and conditions that, in the opinion of the fire code official, constitute a distinct hazard to life or property.”

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Just as in Scenario 1, Items 3 and 4 would also apply to Scenario 2. Additionally, Item 1 would also apply to the work being performed in the building (since it is creating a new condition). Therefore, any requirement found in the IFC that is applicable to a system or component within the work being performed is applicable. This means you’ll need to review the IFC chapters that are relevant to the given system or component of your building under consideration to determine if there are any applicable requirements.

​IFC Administrative, Operational and Maintenance Provisions

​Per IFC Section 102.2, the administrative, operational and maintenance provisions of the IFC “apply to:

1. Conditions and operations arising after the adoption of this code.
2. Existing conditions and operations.”

Similar to our Scenario 1 case, both of these items apply to Scenario 2. 

​What about NFPA 1

There are requirements throughout NFPA 1 that would apply to Scenario 2, so again you’ll need review the chapters that are relevant to the given system or component of your building that will be changed and find the requirements for existing buildings within those chapters.

​Conclusion

The phrase “meeting code” is used frequently in the A/E/C world but depending on the nature of your building and the work being performed, it can mean many different things!
For an existing building, you likely fall under one of these two scenarios:

• Scenario 1: Normal Operation of an Existing Building
• Scenario 2: Changes to an Existing Building

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Scenario 1 typically requires compliance only with certain portions of the IFC. Scenario 2 requires compliance with the IEBC and the IFC. If you are in a jurisdiction enforcing NFPA 1 and 101, there are also requirements from these codes that apply to both scenarios.