Navigating the Building Code Minefield

Every couple of years the building codes for each state are revised to reflect modern building construction and fire safety science. In this article, we will try to make you aware of many of these common issues — to make you aware as you communicate with your design professional, as well as to help prevent an accidental wrong step that might hinder your building project.


The Kannapolis Fire Station 3 apparatus bay is considered a storage (S-2) occupancy.

The first concept to recognize is the fact that a fire station actually consists of several different uses — referred to as “occupancies.” We will typically see three or four occupancy classifications in most fire stations. The first is the apparatus bay, which is a Storage (S-2) occupancy, treated no differently than an enclosed parking garage. The second is the sleep rooms, which will fall into a residential classification (R-2). The third is the office/administrative portion of the fire station which will be classified as business (B). The last is any training, community or other assembly space that will hold 50 or more persons. This is known as an assembly (A-3) occupancy. Rooms holding less than 50 persons can normally be classified as part of the previous business occupancy — an example being a typical conference room.

I know you’re thinking, “This is exciting! But an article about new hot/cold zones or COVID safety would be more interesting.” Stick with me on this. The reason I explain all of the occupancies, is that these are the basis for many of the code issues that will be discussed.

Each of the above occupancies are treated with differing requirements by the code and will require planning to ensure that the overall facility does not exceed the maximum building size, as allowed for each type of construction – combustible (wood) or non- combustible — concrete, masonry or steel — by the code. When it comes to the different occupancies, the design professional will have two choices which will affect the flexibility and cost of your building. If the overall size of the building or the individual occupancy components do not get too large, you will have the option of building a facility that is a “non-separated- mixed-use” facility, or in simpler terms a facility that fits into the size and construction requirements of the most stringent occupancy.

The other option is to separate the different uses with fire resistant (rated) walls ranging from one to two hours and providing rated doors, openings and duct fire dampers between these spaces. If looking only at the economy of materials and door systems, and the new facility can meet the size requirements to be “non-separated” there may be some cost savings with the “not- separated” route and it may also have the added benefit of allowing more flexibility. But do not get your hopes all the way up. Even if you can discard all of your rated walls above, the code will throw some specific wall rating requirements at you that you will not be able run from. We will discuss several of these in the following sections.

In the past, the building code required a two-hour fire resistant separation between the vehicles and the remainder of the facility due to the inherent dangers of the equipment parked there. Our current codes have since removed this direct requirement, pointing us back to the requirements discussed above concerning separated or non-separated mixed- use buildings, this will remove the rated requirement the majority of the time. Even though we have seen the rated separation removed, good practice will probably still mean you are building an air tight non-combustible separation — just not rated. Another change in the requirements of the apparatus bay design is the allowable size without sprinkling (the bay). If the apparatus bay is over 12,000 square feet, the entire bay will have to be constructed with fire sprinklers. Another is that the bays will have to have automatic ventilation for both carbon monoxide build up and for exhaust fumes (NFPA). Your designer can assist you with the different options available for these ranging from point capture systems — PlymoVent is a common manufacturer — in-bay filtration systems and/or using building mechanical systems. If any of your vehicle bays are going to be for repairs, continuous ventilation requirements will need to be addressed along with the above.

Although we may not have to provide a fire sprinkler in the apparatus bays, the sleep rooms will now require one. Per the current codes any sleep room or R-2 occupancy is required to be sprinkled. There are options available to use a 13R system which can help where there is no municipal water system, but to make this accommodation a fire wall would need to separate the R-2 space from other areas of the facility. Also, do not forget that a non-fully sprinkled facility severally reduces the allowable building areas which can impact whether or not you have to provide rated separation walls between the different occupancies. Corridors in the residential or sleep room portion of the project (R-2) and walls separating the sleep rooms may have to be constructed with one-half or one-hour fire resistant construction protecting it from the adjacent spaces. Several other requirements to keep in mind will be the requirement for carbon monoxide detectors and alarm strobes in each sleeping area or room.

The corridors in the Office areas (B) have a similar requirement as the residential for a one-hour fire resistant rating, the difference is that it is not required if the business section of the building is sprinkled or the corridor does not serve more the 30 persons. The kitchen in the station also falls under the business portion of the facility. Where previous versions of the building codes have had requirements for commercial hoods and suppression systems and then at a point had vaguely worded exceptions for this, the current code is much clearer. The current code clearly states that where domestic cooking equipment — not commercial — is used, the installation of a ventilation fan simply needs to meet the manufacturers requirement which is typically a simple residential range hood. However, once you install your luxurious Viking 12 burner gas range, or any commercial cooking equipment, you will be required to install a suppression hood. A side note that can become challenging is that the controls for the residential exhaust hood need to be down at ADA height!

The Mount Pleasant South Carolina Fire Station 6 kitchen and dining room is given a business (B) occupancy.

When you start looking at the assembly spaces (A-3) in your facility remember that this includes ANY space that you would congregate 50 or more persons. Examples of these spaces are training rooms, community rooms and even possibly even weight rooms. It is based on code mandated occupancy rates of how many persons could fit in the space — and not how many you are planning on using the space. Again, the requirement of fire rated corridors will come into play in this area. Also exits will play a larger role in planning these areas. Rooms used for large groups will often have to have a minimum of two exits from each room, possibly more depending on the size of the room. Also, if any of the doors will provide exiting for 50 or more people, the door will have to swing out of the room it is serving instead of swinging into the room as most interior doors do.

Another common adjacency that may require separation, depending on the view of the local building inspector, is the possibility of a satellite police substation. We see many communities considering this as way to meet additional needs, without building additional facilities. This arrangement however, may require a tenant separation wall of one-hour fire resistant construction.

Site constraints or program needs forcing you to go two stories with your new station? If you are considering a two-story facility, go ahead and plan on the cost and space requirements of an elevator, along with the stairs! We have reviewed this with many states including North and South Carolina, you WILL be required to have an elevator.

The reasoning is that the upper level needs to be accessible, even if it is an area of the station with bunks rooms only for line firefighters. There is the real possibility that a temporary injury might affect a firefighter, where he may still pull duty and use the upstairs. Also, with many stations serving as shelters during emergencies or natural disasters, others besides the firefighters may need access to these spaces.

Another item to consider if you have multiple levels — in some jurisdictions this may consider any storage mezzanines — is that these may be required to have an “area of rescue assistance,” spaces large enough for a person in a wheelchair to seek refuge for a one-hour period to await rescue. This space is needed when a person does not have direct access, without stairs or elevators to a safe passage out of the building. The area of rescue assistance also requires a two-way communication system to notify firefighters of an individual requiring assistance or rescue. This requirement usually is omitted if the FULL building is sprinkled.

Lastly, did we mention storm shelters? A request we are seeing more and more is the request for either the full building to be built to meet — in our coastal communities —higher then code required wind speeds up to a 200 m.p.h. Category 5 hurricane or at least a smaller portion to be built as a “storm shelter” as a refuge for the staff in the event of a catastrophic storm. Today’s building codes now addresses this. Any fire station — or 911 or police station — being built where the ICC 500 wind speed for tornadoes exceeds 250 m.p.h. is required to be built wholly or partially as an ICC 500 Storm Shelter. The good news is that if you review the ICC 500 tornado wind speeds both North and South Carolina are specified as a maximum of 200 m.p.h., below the requirement. Therefore, at this time, there is no mandatory requirement of the building code for a storm shelter. If you are planning a new station in northwest Georgia, Alabama, Mississippi, and Louisiana and other states in the west, there is a good chance this requirement will impact you.

These are just a small number of the major areas of the new code that will play an important role in your next building project. It is important to view the new code as a tool to help with your new facility and not a hindrance to meeting your needs or the design.

This new code has many options on how to address different situations, as fire sprinkling the entire facility will change the dynamics of many of the requirements discussed above. You as the owner and end user will be able to communicate more

effectively with your design professional, will have a better facility and better chance avoiding some of the major building code land mines that have the potential of derailing your next project if you are aware of the major requirements and how they affect you.

Jim Stumbo is a partner and Principal with Stewart-Cooper-Newell Architects. He has developed a national reputation for his expertise in the efficient and effective design of Public Safety facilities, including Law Enforcement, 911/EOC, Fire Stations and Training Facilities. Stumbo is a University of Tennessee alumnus, and has written professional articles on design for regional Fire and Rescue publications. He enjoys teaching design courses at regional and national Fire and Law Enforcement conferences.

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