Codes for Existing Buildings, Normal Operation?

MeyerFire University | LS001.05B

By Chris Campbell, PE

RESOURCES

• One-Page Summary [PDF]
• Notes Page [PDF]

CODE & STANDARD REFERENCES

• NFPA 101 – 2021: Section 7.1.1 Example of section that applies to both new and existing buildings
• IBC – 2021: Section 102.6 – Structures as is unless required by the fire code or threat per AHJ
• IEBC – 2021: Section 101.2 – IEBC applies to modification of buildings
• IFC – 2021: Section 102.1 – Applies IFC where there is a distinct hazard to life or property
• IFC – 2021: Section 102.2 – Operational, admin., & maint. provisions apply to existing buildings

---

TRANSCRIPT

What building code applies to my existing building? 

INTRO

If you’ve spent any amount of time in existing buildings, you’ve probably heard the concept of the building “meeting code” come 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. 

This video will be the first of two videos where we will explore various building and fire codes that could apply to your existing building. There are many other codes (e.g. electrical or elevator codes) that we won’t specifically address, but the general thought process for those is similar.

This first video will focus on normal operations of an existing building and in the second video, we’ll cover changes to an existing building. 

SCENARIO 1: NORMAL OPERATIONS OF EXISTING BUILDING

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), “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. 

BUILDING OFFICIAL AUTHORITY

For example, IBC section 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 IFC or IPMC, or as is deemed necessary by the building official for the general safety and welfare of the occupants and the public.”

So, in other words, the IBC does not require any change to your building unless there is a specific requirement in the IFC, 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 Official the authority to require a change to your building if they deem it is necessary for safety reasons. 

CODE OFFICIAL EXAMPLE

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. 

IEBC

Similar to this IBC Section, the IEBC has the exact same language in Section 101.4. Additionally, the overall scoping language in IEBC section 101.2 states that the provisions of the IEBC apply to the “repair, alteration, change of occupancy, addition 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. 

Unlike the ICC, which separates the IBC and IEBC into two different codes, NFPA 101 applies to both new and existing buildings.  

NFPA EXAMPLE

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

Next, certain portions of the IFC, the International Fire Code, 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 the code. 
3. Existing structures, facilities and conditions where required in Chapter 11. 
4. Existing structures, facilities and conditions, in the opinion of the fire code official, that constitute a distinct hazard to life or property.” 

In our case where we have normal operations of an existing building, items 1 and 2 above would not apply since we are an existing, permitted building. 

However, items 3 and 4 would apply. 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 FIRE SAFETY AND MEANS OF EGRESS

IFC Chapter 11 primarily focuses on fire safety and means of egress requirements. A few examples include:

• Requiring standpipes in buildings with a floor higher than 50 feet 
• Requiring smoke alarms in Group R and Group I occupancies 
• Requiring guards in the means of egress where the change in level is more than 30 inches 
• Requiring handrails on at least one side of stairways to name a few 

These requirements are fairly basic and are typically 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 present in your building. 

IFC ADMINISTRATIVE, OPERATIONAL AND MAINTENANCE PROVISIONS

Next, IFC Section 102.2 requires the administrative, operational and maintenance provisions of the IFC to apply to:

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

In our case where we have normal operations of an existing building, both of these items would apply. This means that 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 applicable requirements that would need to be met in your building. 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 the equipment that’s in the facility. 

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. 

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. 

SUMMARY

In summary, in this video, we examined code requirements that could apply to your existing building, where you were just performing normal operations in line with the occupancy and use permit for that building. Generally, the IBC and the IEBC do not apply to your building, although in those codes, as well as in the IFC and NFPA 1, the code officials do have power to require a change to your building if they deem there to be a distinct hazard to life or property. Assuming that is not the case, the IFC and NFPA 101 and NFPA 1 all have requirements that could apply to your building. You need to determine which of the chapters within those codes are applicable to your building based on the use and occupancies of the building, and then review those specific chapters to determine if there are requirements that could apply to your building. 

In the next video, we'll cover a situation where you have changes to an existing building and determine what codes apply in that scenario. 

I’m Chris Campbell, this is MeyerFire University.