Level 3 Alteration – A Common Misconception

A common concern raised with some renovation projects is that level 2 alteration work needs to be limited to 50% of the building area; otherwise, the project will be classified as a level 3 alteration and the building will need to be brought up to full compliance with the current code. This is a common misconception that can lead to increased costs and schedule delays both in design and construction. To understand why, it is important to know the following three classifications/definitions from the 2015 International Existing Building Code (IEBC):

  • A level 2 alteration includes the reconfiguration of space, the addition or elimination of any door or window, the reconfiguration or extension of any system, or the installation of any additional equipment (2015 IEBC 504.1).
  • Level 3 alterations apply where the work area exceeds 50 percent of the aggregate building area (2015 IEBC 505.1).
  • A “work area” is defined as the portion or portions of a building consisting of all reconfigured spaces as indicated on the construction documents. Work areas exclude other portions of the building where incidental work entailed by the intended work must be performed and portions of the building where work not initially intended by the owner is specifically required by the IEBC code (2015 IEBC 202).

To have a level 3 alteration, the project needs to have a work area (consisting of reconfigured spaces) that exceeds 50 percent of the aggregate building area. A project could have level 2 alterations in 100% of the building area and not trigger a level 3 alteration. An example would be the installation of a new sprinkler system throughout the building without any other alterations occurring.

Another concept is that the work area does not include unintended work. For example, if the project triggers upgrades in other areas of the building, such as accessibility upgrades, these areas would not be considered part of the project work area – and therefore not contribute to the 50% calculation.

Lastly, if the project does include a level 3 alteration, the building is not required to be brought up to full compliance with the current code. The requirements associated with level 3 alterations are intended to improve the safety of certain building features beyond the work area and in other parts of the building where no alteration work might be taking place. Similar to going from a level 1 alteration to a level 2 alteration, there are additional requirements when a project changes to a level 3 alteration; however, the code does not require the entirety of the building to be brought up to full compliance with the code for new construction.