New BBRS Interpretation Clarifies Existing Building Requirements

On February 11th, the Board of Building Regulations & Standards (BBRS) released an official interpretation to clarify requirements for existing buildings. This latest interpretation is one of the most significant to date as it addresses 4 key points associated with 780 CMR 34 (2009 International Existing Building Code with MA Amendments). Here’s what you need to know:

  1. Compliance Alternatives – Compliance Alternatives, developed for existing buildings where the code for new construction cannot be met, are NOT required to be issued by a registered design professional. With that said, the services of a registered design professional may be warranted for complex issues that require a specific knowledge or area of expertise.
  2. Sprinkler Protection in Existing Buildings Undergoing a Change in Use – The extent of sprinkler protection required in existing buildings undergoing a change in use has been widely misunderstood. IEBC Section 912.1.1.2 specifies that the extent of sprinkler protection is limited to the area undergoing the change in use where separated by fire rated construction from the remainder of the building. However, this approach conflicts with the general notion in Massachusetts that multiple fire areas cannot be created to prevent sprinkler requirements as noted in 780 CMR 903.2. The interpretation clarifies that the extent of sprinkler protection required may be limited to only the areas undergoing the change in use in the existing building by using the building separation method as described in IEBC Section 912.1.1.2. Note that sprinkler protection may still be required throughout the entire building by MGL Chapter 148 Section 26G if the building totals more than 7,500 gross square feet and is undergoing a “major alteration”. Official guidance on MGL Ch.148 S.26G can be found here:
  3. Multiple Levels of Alteration – A project issued under a single permit may indicate several different levels of alterations. For example, a building being altered with a portion of the electrical system being replaced on the first floor and the construction of a new room on second floor would be classified as a Level 1 Alteration and a Level 2 Alteration. The work occurring on the first floor would be considered as a Level 1 Alteration due to the replacement of an existing system serving the same purpose, and the work on the second floor would be considered as a Level 2 Alteration due to the addition of new walls. Note that although a single permit can include multiple alteration levels, more than one compliance method (such as Work Area Compliance Method and Prescriptive Compliance Method) cannot be used on a single permit.
  4. Definition of Reconfigured Space – The determination of the level of alteration under the Work Area Compliance Method is contingent upon the defining what is considered as the work area. Per IEBC Section 202, the work area is defined as “…all reconfigured spaces as indicated on the construction documents.” Until now, the term “reconfigured space” was ambiguous and left to the building official to interpret. The BBRS has clarified that space is considered as reconfigured if it changes the manner in which occupants egress from the space in terms of travel or distance to exits. This is an important concept to recognize because the work area of a building does not necessarily include all of the areas where work is being done. In the past example in Item #3 above, the work area would consist of the reconfigured room on the second floor only since this is the only space where egress travel and distance has changed. Although work is occurring on the first floor due to replacing the electrical system, this does not include any reconfigured space and thus is not included in the determination of the work area.

Here’s a link to the official BBRS interpretation, which contains useful diagrams illustrating which constitutes reconfigured space:

Application of any information provided, for any use, is at the reader’s risk and without liability to Code Red Consultants. Code Red Consultants does not warrant the accuracy of any information contained in this blog as applicable codes and standards change over time. The application, enforcement and interpretation of codes and standards may vary between Authorities Having Jurisdiction and for this reason, registered design professionals should be consulted to determine the appropriate application of codes and standards to a specific scope of work.