NIST

PUBLICATION^!

NBS SPECIAL PUBLICATION 549

Proceedings of the National

Conference on Regulatory Aspects

of Building Rehabilitation

U.S. DEPARTMENT OF COMMERCE/National Bureau of Standards
NATIONAL BUREAU OF STANDARDS

The National Bureau of Standards' was established by an act ot Congress on March 3, 1901.

The Bureau's overall goal is to strengthen and advance the Nation's science and technology

and facilitate their effective application for public benefit. To this end, the Bureau conducts

research and provides: (1) a basis for the Nation's physical measurement system, (2) scientific and technological services for industry and government, (3) a technical basis for equity in trade, and (4) technical services to promote public safety. The Bureau's technical work is per- formed by the National Measurement Laboratory, the National Engineering Laboratory, and

the Institute for Computer Sciences and Technology.

THE NATIONAL MEASUREMENT LABORATORY provides the national system of

physical and chemical and materials measurement; coordinates the system with measurement

systems of other nations and furnishes essential services leading to accurate and uniform

physical and chemical measurement throughout the Nation's scientific community, industry,

and commerce; conducts materials research leading to improved methods of measurement,

standards, and data on the properties of materials needed by industry, commerce, educational

institutions, and Government; provides advisory and research services to other Government

agencies; develops, produces, and distributes Standard Reference Materials; and provides

calibration services. The Laboratory consists of the following centers:

Absolute Physical Quantities^ — Radiation Research — Thermodynamics and

Molecular Science — Analytical Chemistry — Materials Science.

THE NATIONAL ENGINEERING LABORATORY provides technology and technical ser- vices to the public and private sectors to address national needs and to solve national

problems; conducts research in engineering and applied science in support of these efforts; builds and maintains competence in the necessary disciplines required to carry out this research and technical service; develops engineering data and measurement capabilities;

provides engineering measurement traceability services; develops test methods and proposes

engineering standards and code changes; develops and proposes new engineering practices;

and develops and improves mechanisms to transfer results of its research to the ultimate user. The Laboratory consists of the following centers:

Applied Mathematics — Electronics and Electrical Engineering^ — Mechanical

Engineering and Process Technology' — Building Technology — Fire Research —

Consumer Product Technology — Field Methods.

THE INSTITUTE FOR COMPUTER SCIENCES AND TECHNOLOGY conducts

research and provides scientific and technical services to aid Fedei-al agencies in the selection,

acquisition, application, and use of computer technology to improve effectiveness and

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relevant Executive Orders, and other directives; carries out this mission by managing the

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The Institute consists of the following centers:

Programming Science and Technology — Computer Systems Engineering.

'Headquarters and Laboratories at Gaithersburg, MD, unless otherwise noted; mailing address Washington, DC 20234. 'Some divisions within the center are located at Boulder, CO 80303.
Proceedings of the National

Conference on Regulatory Aspects

of Building Rehabilitation

Held at the National Bureau of Standards

October 30, 1978

Sandra A. Berry, Editor

Building Economics and Regulatory Technology Division

Center for Building Technology

National Engineering Laboratory

National Bureau of Standards

Washington, D.C. 20234

U.S. DEPARTMENT OF COMMERCE, Juanita M. Kreps, Secretary

Luther H. Hodges, Jr., Under Secretary

Jordan J. Baruch, Assistant Secretary for Science and Technology

NATIONAL BUREAU OF STANDARDS, Ernest Ambler, Director

Issued August 1979
Library of Congress Catalog Card Number: 79-600095

National Bureau of Standards Special Publication 549

Nat. Bur. Stand. (U.S.), Spec. Publ. 549, 220 pages (Aug. 1979)

CODEN: XNBSAV

U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON: 1979

For sale by the Superintendent of Documents, U.S. Government Printing Office Washington, D.C. 20402 - Price $S. 60

Stock Number 003-003-02107-6

I
Preface

?^u^e,nt CcUiteA and tkt Cong/iUA havz caJUtd ioK g^zatly ^ncAta&zd mpha&^

on KehabiJUtcvt^Yi OjJ txJjbtbiQ kou^-ing to KohuuZd thz Katlon'-i neAjghboJihoods

,

In othoji occupancy cZaiA^^^cationi a& {^}zZt, tkz economic lacXoni> yinvolvzd

kavt tzd to tkz /LZiUt OfJ zxA^ting balZding^t and o^zn a ^ubAzqucnt changz Xn

oc,mpancy cZa&^l^at^on* In many ol the, Hation^i^ (^ctcei, tkz. Kekab^tUation OjJ zxyl&ting .itnactuAU hoA tuAncd waJidioa&2>& -into 4fco)04 and Hjttt(iuiAant&,

dl&4ntzgAattd KJ^MdnXJiat city btocki M.o &hoppmg maJUU, 6tnglc- ^anuJiy

hornet Mo AuAtzi o^ pKo^z&6AX>naZ oi^tczi, coanthouAeAi into day coAt ^acUUtiu, ztc,

?.tgiiJMofijy pKjobtom kavc bzen ldmti^A,zd a6 impacting tkz ^zhabiJUtation o£

zxA^ting bvUZding-i, Tkz&z pKoblmb OM, caaizd by: {1) ajpplLcjation ol codoM

ioK new con&tmc^on to exl&ting buUZd^ng^; (2) lack o£ a tzchnlcat ba^i^

io^ \)aAA,ouA codz pH.ovA^ton&; (3) an uncZzoA code zn£oAczmznt p^oce^A ^oK.

6omz typzi> ol coYi&tnjuuction AzpA,z&zntzd am many oldzn. biUldlng'i; and, [4] a

iack ol vatid zvaJbjuoution meXhod& ^on. zxA^ting con&tAactton.

Thz National Con^eAzncz on RzguZato^y A&pzct6 o^ SiUlxjUng RekabAJUtation

covUtAjdzKzd thz&z ti6ue>& KzZatxvz to thz KzhabttltatyLon o^ buXtding-i In thAzz

paAt&i

Sz&6i,on on Codz VnjovAjt>lom and Thzin. Impact

Sz64iton on TzchntcaJi Evaluation Guidzlinzi and TheJji Vzvzlopmznt

Sz64)ton on AdminA^tAcutivz ?H.oczduAZ& and ThziA E^^zctivznz&6

Thz ton^zAzncz woi dz&tgnzd to bfung togztkeA all panties concznnzd with thz

fLzgutatoKy oipecti o^ buitding AeJiabtlItatA,on to AhoAz knoMlzdgz and zxpeA-

-tencei oa MeJll a& to gain additional in&tght on ongoing pAognjomd at thz

Statz and VzdeAaZ Izvzl tn this 'iubjzct a/iza,

A majofL topic OjJ dU^cvus&ijon at tkz con^zAzncz woi thz Ma&'i>achu6ettA Building RekabiJUtatlon Pilot PAOjZct. Thz pfiojzcjt IncZudzd a fizvlew o^ thz

Mai6adiu6ztt4> Statz Building Codz and Its Impact on zxt&tlng buiZdlng^, and

thz dzvzlopmznt o^ new codz pAovl&lom ^o^ thz administration o^ builxUng

rehabilitation .

Thanks a/uz zxtzndzd to alt thz sponsors o^ this con^zJizncz:

AA6ociatlon o^ Major City Building O^f^claJU

Building O^^cials and Codz AdminlitAaton Jntzfmatlonal, Inc.

IntzmatlonaJt Con^zrencz oi Building O^lcials

National Academy o^ Codz Adminl&tAotlon

National Kd&ocAJxtion oi Housing and Rzdzvzlopmznt O^^ciats

National BuJiema OjJ Standards

National Con^zrencz OjJ Statzs on Building Codes and Standards, Inc.

Southern Building Codz Congress Jntzmatlonal, Inc.
App/izcMxXxon AJ> zxp^t&6zd {^on. thz ^nvaJimblz corit/uhutyioiU the AjidivAAwaJi

6pQjaiiQAA and thz a.cti\}Z pa/vtlclpcution oj^ thz othex cutttndzt& In tho. paneJi

dLUcai>6A,oyi!>, iMkick coZtzc;tLveZy made, thu a tlmeJiy, AM{fOnmaXJ,vz, and ijoditn.zc<Ll\}zd con^eAznaz,

SpzcylaJi thanks and ^zcogtvUxon duz JowieA H. ?A,2ZQAt, Gnxjwp IzjodoA, BiUldXng RekabAMXation Tzdknology, {^ofi ohQanizlYiQ tlfUA day-long 4eA4>cow, ^ox

de.veJiopme.yit o{, the. cowjJeAence agenda which 4>uccAnctJiy add/iz&4>zd thU divex&e.

and {^onrK-zaahlng ^ubjzct, and Ion. peA&onat Ajivotvemejnt tn pfiocuAAjig a va/Uety 0^ .ipeAkeJii u)ko-i>z pA.e^entatton6 6o welt de.^tmd the. 6tatz-o{i-the.ra/it tn

the. buUZding nehabttltation 6ubjzct an.exi.

We. have. be.zn de.e.ply 4>addzne.d by thz unttmeZy death on fehfmahjy 20, 1979, ojj

ouA Kzynote. Spe.akeA, NathanA,eZ H. Rogg. Vk, Rogg um uitdeZy n.tcognlze.d Ion.

ki& Zong-teAm cont/UJbutton to hou&tng and ^on. hZi nzcent e,iiont& tn xzgaAd

to buUldlng nzhabAJUXatlon, which fie 4o z{i^zctlveJiy 4>haA.e,d w/Jk ai in his

Ke.ynote. kddJieA>i>.

Jame.& G. Gnoi>^, Chie.^

Bultdlng Economics and Re.guJiaton.y

Technology Vlvtiton

Centex ^on Bvulding Technology

National EngyinteAying Labonaton.y

National Bane.aa o^ Standandi

vl
Table of Contents

Page

PREFACE V

TABLE OF CONTENTS vii

SI CONVERSION ix

BACKGROUND 1

OPENING SESSION

Introduction to Conference by James G. Gross 3

Welcome to the National Bureau of Standards

by James R. Wright 5

KEYNOTE ADDRESS

By Nathaniel Rogg, Consultant, Former Vice President of

National Association of Home Builders 7

OVERVIEW OF MASSACHUSETTS PILOT PROJECT

By Charles J. Dlnezlo 15

PUBLIC PROGRAMS FOR HOUSING REHABILITATION

By Anita Rechler 19

HUD REHABILITATION GUIDELINES

By Robert J. Kapsch 23

SESSION ON CODE PROVISIONS AND THEIR IMPACT 29

Moderator: T. H. "Nick" Carter 31

Application of Article 22 of the Massachusetts State

Building Code by Paul Folklns 33

Impact of New Construction Oriented Codes on Building

Rehabilitation by Richard P. Kuchnlckl 39

Code Requirements for Existing Buildings: A New

Approach by Kenneth M. Schoonover 43

Panel Discussion 51

vii
CONTENTS - (continued)

Page

SESSION ON TECHNICAL EVALUATION GUIDELINES AND THEIR DEVELOPMENT . . 65

Moderator: James H. Pielert 67

A "Professional Practice" Approach to the Rehabilitation

Process by Walter E. Lewis 71

A Fire Evaluation System for Health Care Facilities

By Harold E. Nelson 85

Rehabilitation Standards: What Are They? Who is to Develop,

Maintain, and Enforce Them? by Bernard A. Cummings . 103

Panel Discussion 107

SESSION ON ADMINISTRATIVE PROCEDURES AND THEIR EFFECTIVENESS .... Ill

Moderator: William Plouffe 113

Rehabilitation, Performance and the 'Real World' of the Code

Official by Joseph Stein 119

An Architect's View of Rehabilitation Regulation

By Frederick A. Stahl 125

Administration of a Rehabilitation Code in a Major City

By Creighton C. Lederer 131

Panel Discussion 135

APPENDIX A - Attendees 137

APPENDIX B - Article 22, Massachusetts State Building Code 141

Reference Standard RS 22-1 159

Reference Standard RS 22-2 171

Reference Standard RS 22-3 183

Reference Standard RS 22-4 199

viii
Metric (SI) Units

The following list of conversion factors for the most frequently

used quantities in building design and construction may be used.

QUANTITY

LENGTH

AREA

VOLUME

CAPACITY

VELOCITY, SPEED

ACCELERATION

MASS

DENSITY

FORCE

MOMENT OF FORCE . TORQUE

PRESSURE. STRESS

WORK, ENERGY . QUA,NTITY OF HEAT

POWER, HEAT FlOU

RATE

INTERNATIONAL (SI) UNIT

meter (m) minimeter (mm)

square meter (m')

square millimeter (nn')

cubic meter (m')

cubic millimeter (mm')

liter (L) milliliter (mL)

meter per second (m/s)

kilometer per hour (km/h)

U.S. CUSTOMARY UNIT

foot (ft)

inch (in)

square yard (yd* square foot (ft', square inch (in*)

cubic yard (yd')

cubic foot (ft')

cubic inch (in')

gallon Igal)

fluid ounce (fl 02)

foot per second (ft/s or f.p.s.)

mile per hour (mile/h or m.p.h.)

APPROXIMATE CONVERSION

meter per second squared (m/s*) foot per second squared (ft/s'l

metric ton (t) [1000 kg]

ki logram (kg) gram (g)

metric ton per cubic mrter (t/m')

kilogram per cubic meter (kg/m')

kilonewton (kN)

newton (N)

kilonewton meter (kN*m) newton meter (N'm)

megapascal (MPa)

kilopascal (kPa)

megajoule (Kl)

kilojoule (kJ)

joule (J)

kilowatt (kW) watt (W)

COEFFICIENT OF HEAT watt per square meter kelvin TRANSFER [U-value] (W/m'-K) t= (W/m'-'C)]

THERMAL CONDUC- watt per meter kelvin (W/m-K) TIVITY [k-value] ['(W/m-'C)]

short ton [2000 lb]

pound (lb) ounce (oz)

ton per cubic yard (ton/yd')

pound per cubic foot (lb/ft')

ton-force (tonf)

kip [1000 Ibf]

pound-force (Ibf)

ton-force foot (tonf'ft)

pound-force inch (lbf*in)

ton-force per square inch (tonf/in*)

ton-force per square foot (tonf/ft*)

pound-force per square inch (Ibf/in*)

pound-force per square foot (Ibf/ft*)

kilowatthour (kWh)

British thermal unit (Btu)

foot pound-force (ft* Ibf)

horsepower (hp)

British thermal unit per hour (Btu/h)

foot pound-force per second (ft*lbf/s)

Btu per square foot hour degree

Fahrenheit (Btu/ft'-h'-F)

Btu per square (Btu/ft'^T)

m s 3.2808 ft nn - ~ 0.0394 in

m* = 1.1960 yd'

m' 10.764 ft* mn' _ 1.5500 X lO'^in'

m' = 1.3080 yd'

m' 35.315 ft' nm' 61 .024 X lO'^in'

L 0.2642 aayu 11 mL = 0.0338 fl oz

m/ s 3.2808 ft/s

km/h 0.6214 mi le/h

m/s* = 3.2808 ft/s*

t 1 .1023 ton

kg 2.2046 lb

9

= 0.0353 oz

t/m' 0.8428 ton/yd'

kg/m' 0.0624 lb/ft'

kN 0.1124 tonf

kN = 0.2248 kip

N 0.2248 Ibf

kN-m _ 0.3688 tonf'ft

N*m 8.8508 Ibf'in

MPa 0.0725 tonf/in*

MPa 10.443 tonf/ft*

kPa 0.1450 Ibf/in*

kPa 20.885 Ibf/ft*

MJ 0.2778 kWh

kJ 0.9478 Btu

J 0.7376 fflbf

kW 1.3410 hp W 3.4121 Btu/h

W 0.7376 fflbf/s

W/m'-K 0.1761 Btu/ft'«h'»F

W/m'K 0.5778 Btu/ft*'°F

NOTES: (1) The above conversion factors are shown to three or four places of decimals.

(2) Unprefixed SI units are underlined. (The kilogram, although prefixed. Is an SI base unit.)

REFERENCES: NBS Guidelines for the Use of the Metric System, LC1056, Revised August 1977; The Metric System of Measurement, Federal Register Notice of October 26, 1977, LC 1078, Revised November 1977; NBS Special Publication 330, "The International System of Units (SI)," 1977 Edition; NBS Technical Note 938, "Recommended Practice for the Use of Metric (SI) Units in Building Design and Construction," Revised edition June 1977; ASTM Standard E621-78, "Standard Practice for the Use of Metric (SI) Units in Building Design and Construction," (based on NBS TN 938), March 1978; ANSI Z210. 1-1976, "American National Standard for Metric Practice;" also Issued as ASTM E380-76^, or IEEE Std. 268-1976.

ix

Background

Abstract: This document contains the edited Proceedings of the National

Conference on Regulatory Aspects of Building Rehabilitation

held October 30, 1978, at the National Bureau of Standards.

It contains a total of 18 presented papers, all of which

address the subject of rehabilitation—currently a critical

issue in the Nation's effort to revitalize its cities and

house its citizens.

Public sector, as well as private sector programs and experiences

toward achieving this goal are covered in one general and three

technical sessions.

Key Words: Building; code administration; codes; evaluation; existing

buildings; performance standard.

These Proceedings report on a year-long series of activities which address

the issue of the impact of the regulatory process on the rehabilitation of

existing buildings. The purpose of this introduction is to outline the

activities to provide a better understanding of the papers included in

these Proceedings.

In the fall of 1977, the National Bureau of Standards (NBS) initiated a

study of the nationally-recognized model building code organizations, and

selected State and major city building regulatory agencies to determine their

needs in regard to rehabilitation of existing buildings. This study identified needs in three major areas:

1. Code Provisions

• technical bases for elimination or modification of the 25-50

percent rule

• performance requirements for existing buildings

2. Technical Requirements

• methods for evaluation of existing construction

• validation of technical constraints for various occupancies

• catalog of data on building systems no longer in use

3. Regulatory Process

• improved process for existing buildings to replace the current

ad hoc system

These results were the basis for the establishment of the Building

Rehabilitation Technology Group in the NBS Center for Building Technology

in October 1978.

1
While reviewing the results of this study, concerned officials in the State

of Massachusetts determined that the State could benefit by a review of its

existing building code and the subsequent adoption of interim building rehabilitation guidelines. A team of building regulatory-related organizations

was established to work with the State in this effort. The National Bureau

of Standards provided technical support to the team in its development of

the interim code provisions.

These provisions were to become a part of the Massachusetts State Building

Code—Article 22. The final draft of proposed Article 22 of the Massachusetts

State Building Code entitled, "Repair, Alteration, Additions and Change in

Use of Existing Buildings," was submitted on October 23, 1978, to the State

Building Code Commission by the developing team. This document is included

as Appendix B to these Proceedings.

The code concept contained in Article 22 no longer uses the amoimt of

work vmdertaken on an existing building as a basis for determining the

degree of compliance with the code for new construction. Instead, it is

the intent of Article 22 to allow repairs, alterations, additions to, and

change in use of, existing buildings without meeting all new construction

requirements under the following general conditions

1. all hazardous conditions must be corrected,

2. the existing building becomes the minimum performance standard,

and

3. the degree of compliance of the building after changes must not be

below that existing before the changes.

After public hearings in Massachusetts and review by the State Building

Code Commission, the draft Article 22 was revised by the project team.

The final Article 22 was adopted by the Commission and was printed as part

of the third edition of the Massachusetts State Building Code. The Commission has established a committee to review and update Article 22 based

on implementation experience. The committee met for the first time on

March 29, 1979.

This National Conference on Regulatory Aspects of Building Rehabilitation,

held October 30, 1978, at the National Bureau of Standards, was structured

to provide an overview of regulatory aspects of building rehabilitation

activities in the United States and specific details in the development

and content of Article 22. The papers in these Proceedings should be read

consecutively to obtain a clear understanding of this activity which could

have a significant impact on the re-use of the Nation's building stock.

2
Introduction to Conference

by

James G. Gross

Chief, Building Economics and Regulatory Technology Division

Center for Building Technology

National Engineering Laboratory

National Bureau of Standards

Mr. Gross earned a B.S. in Architectural

Engineering from North Dakota State

University In 1954.

Mr. Gross joined the staff of the Center

for Building Technology in 1971 . He has

held various management positions relative

to CBT work in building regulations , standards participation, building code services,

research related to the development of

building codes and standards, and housing

technology. He is currently the Chief of

the Building Economics and Regulatory

Technology Division, managing CBT work related to building economics , solar energy

standards and criteria, regulatory technology, and building rehabilitation technology

.

Prior to joining NBS , Mr. Gross served as

Director of Engineering and Research for

Precast Systems, Inc., and for many years

as Director of Engineering and Technology

for the Structural Clay Products Institute.

He is a registered professional engineer,

is active in many construction Industry and

professional organizations , and is the

author of numerous technical publications

and articles.

Two of the Nation's more pressing societal problems are insufficient housing

and urban decay. Not only is there a lack of housing to meet the current

demands, but the costs are high and rising more rapidly than income. Urban

revitalization is needed to enrich the quality of life in our inner cities

and to provide a tax base to support the necessary municipal services. The

solution to these two problems may lie in a large part on the effective use of

our existing building stock. A successful national program of rehabilitation

and re-use of buildings of all types, housing and nonresidential buildings,

is a major national need.

Building regulations and their enforcement have been identified by many

and widely cited in the literature as impediments to rehabilitation. This

is not a new finding. It is discussed in the literature of the 1930' s. In

1968, the Douglas Commission reported, and I quote:
"There Is widespread recognition among code experts that current

code standards, which are intended for new construction, should

not be applied literally to the alteration of existing buildings.

Administrators of the rehabilitation programs in cities throughout

the country have found that costs become excessive when present

building code standards are followed,"!^/

Nevertheless, it is widely acknowledged that the problems continue to exist.

One of the consequences is that we continue to demolish and otherwise lose

approximately 850,000 housing units each year, many of which could be saved,

rehabilitated and reused; instead we continue to squander this valuable

resource. There is, however, an increasing awareness of the need to

conserve and re-use our existing buildings. This is true in all levels of

government—Congress, the Administration, various Federal agencies. State

government, city and local jurisdictions. The private sector, too, is

becoming increasingly interested in solving the societal problems of

insufficient housing and urban decay.

The magnitude of building rehabilitation today is not small by any means.

The current level of housing maintenance and repair is estimated to be

$38 billion per year, while the total dollar expenditure for new housing

construction is currently running at the rate of $78 billion per year;

or, in other words, the rehabilitation and remodeling market is roughly

one-half of the new construction market in housing, George Christie,

Chief Economist of McGraw-Hill Information Systems, estimates another $15

billion is currently being spent on nonresidential rehabilitation.

Further, the rehabilitation and remodeling has been increasing at a more

rapid rate and is expected to continue. Obviously, attempts to improve the

rehab climate are of great interest to builders, designers and planners,

industry, building regulators, and other government officials.

Today, we want to focus on the regulatory aspects of the problem in

general and, in particular, we want to share with you the results to date

of a pilot project aimed at removal of regulatory impediments, with the

thought that this pilot project has national implementation implications.

During this discussion, we will talk both about the products used for

regulating rehabilitation and the processes of applying those regulations.

We have attempted to structure today's program to encourage your participation. We hope that you will bring your concerns and questions to the

attention of the speakers.

Xj National Commission on Urban Problems, Building the American City , Report of the National Commission on Urban Problems to the Congress

and to the President, 1968.

4
Welcome to the National Bureau of Standards

by

James R. Wright

Deputy Director

National Engineering Laboratory

National Bureau of Standards

Dr. Wright received a Ph.D. from the

University of Delaware in 1951, with a

major in organic chemistry.

He came to the National Bureau of Standards

in 1960 as a chemist in the Building Research Division; became Assistant Chief of

the Organic Building Materials Section;

Assistant to the Chief of the Building Research Division; and then Chief of the

Division. More recently, he became Deputy

Director of the Institute for Applied

Technology; and currently is the Deputy

Director of the National Engineering

Laboratory

.

Dr. Wright received the Department of

Commerce Gold Medal Award in 1975. He has

held membership in a number of national

scientific and engineering societies , as

well as the International Union of Laboratories for Testing and Research for Materials and Structures.

Dr. Wright holds 27 U.S. and foreign patents

and has published an even larger number of

scientific and technical papers.

I am very pleased to be here today and to have the honor of meeting you

the members of the building community concerned with the growing trend

towards the rehabilitation of structures.

On behalf of Dr. Ambler, the Director of the National Bureau of Standards,

and Dr. John Lyons, the Director of the National Engineering Laboratory,

who unfortunately cannot be here today, I would like to welcome you to the

National Bureau of Standards for this Conference on the Regulatory Aspects

of Building Rehabilitation.

NBS and the other co-sponsors feel that this Conference is particularly

significant because of the greatly increased emphasis on the re-use of

existing buildings in the United States and the impact on such structures

of building regulations.
The National Bureau of Standards has been in the building research business

since its founding around the turn of the century. Since that time, the

Bureau has undergone a number of organizational changes, the most recent

was completed in early 1978. This reorganization is facilitating our

relationship with the building community, since we are now organized along

functional lines. Technical competencies that have grown up over the years

in various organizational units have been consolidated; and the number of

formal organizational units reduced.

The Bureau's functional activities are now structured within two major

units, called Laboratories. One is the National Measurement Laboratory;

the other is the National Engineering Laboratory. Prior to that, dating

back to 1964, the Bureau was organized into four Institutes: the Institute

for Basic Standards; the Institute for Materials Research; the Institute

for Applied Technology; and, the Institute for Computer Sciences and

Technology

,

The Center for Building Technology is now a component of the new National

Engineering Laboratory (NEL), and can draw upon the expertise of other

components within the Laboratory, such as fire research, electronics,

electrical engineering, mechanical engineering and various other areas of

expertise and academic disciplines. I have available a brief description

of the reorganization. It is in an article called, "A New Look for NBS."

I will leave some of these. So, if you are interested in looking in more

detail at the new structure of NBS, feel free to do so.

The importance of building rehabilitation to the Center for Building

Technology is evidenced by the formation of a Building Rehabilitation

Technology Program within the Center. The objectives of this program

include the development of rehabilitation technology and the tools for

evaluating such technology; the improvement in the technical base for

building regulations, so that the regulatory process becomes more responsive

to today's needs; and, the development of economic and other decision-making

models that support building rehabilitation activities.

It is through this program that technical support has been provided to the

Massachusetts Pilot Project which is the focus for the Conference here

today.

I again bid you welcome to the National Bureau of Standards and wish you

well in your endeavors. I look forward to the results of what I know will

be a successful and timely Conference,

Thank you.

6
Keynote Address

by

Nathaniel Rogg

Consultant

Former Vice President of

National Association of Home Builders

Dr. Rogg received a B.S. (Magna Cum Laude)

from New York University in 1934; a M.S. in

Economics from New York University in 1935;

and, a J.D. from George Washington University in 1951.

Dr. Rogg is an economist , attorney, administrator and teacher. He has written many

articles and made numerous speeches on

housing and economic topics. He is a consultant to other nations on housing problems

and has been a participant in scores of

national and international housing events.

He had nearly 20 years Federal Service beginning in the 1930's, including military

,

and 23 years with the National Association

of Home Builders , serving as its Chief Executive for 12 years.

Currently , Dr. Rogg is an Economic Advisor

and Consultant to Savings and Loan Industry

,

Manufacturing, Development and Mortgage Businesses and Lecturer on Urban topics.

Dr. Rogg is a member of numerous professional organizations and is the author of Urban

Housing Rehabilitation in the United States .

The National Bureau of Standards and the National Conference of States

on Building Codes and Standards deserve to be congratulated, along with

your other sponsors for putting together this long-needed Conference on

the Regulatory Aspects of Building Rehabilitation.

It comes at a time when government regulation is being singled out by many

as responsible for everything—from inflation, the high cost of housing

and living, to the Asian flu. It is a signal opportunity to illustrate

the beneficial aspects of the government regulatory process, emphasize

those elements which can be constructive and facilitating, a situation

which is not always the case today for building and regulatory practices

as they apply to rehabilitation.

7
As you know, from the introduction, I am not an engineer, I am not a

code expert, but I have been an observer of the housing scene and a

student of its complexities for many years. I have some biases; let me

identify some of them. I believe that good housing for all of our people

is an essential element by which to judge how well and whether a society

indeed serves its people.

Much of my lifetime, and virtually all my adult life except for some

military service, has been spent in housing and related fields, whether

studying, teaching, or as an economist and chief executive for many years

for a very remarkable trade association which many of you are acquainted

with—the National Association of Home Builders. Above all else, I live

in a house. I have built two and rehabilitated the one I now live in.

This really rounds out my expertise like it does that of most of the

American people. So I am both an observer and a participant in the housing

scene.

It is obvious that I have no technical expertise; however, last year at

the request of the United States League of Savings Associations, whose

members finance nearly two-thirds of all housing in the U.S., I tried to

see what was actually going on in the rehabilitation field. One thing

learned was that if today's building codes were literally enforced, if

building inspectors worked to the book, as airline controllers sometimes

do, most rehabilitation in urban areas would come to a screeching halt.

In the course of my study, I found a lot of rehabilitation going on—far

more than I had anticipated. While there was much going on, there is

also a general—and somewhat inaccurate—belief that it is not very significant, that rehabilitation per se is not very successful.

The Washington Post on Labor Day—a very dull news day—ran an entire

page two story on the subject, "Is there a back to the city movement?" and

concluded, "probably not." They illuminated the story with a picture of

me saying that there was a lot going on and that the statistics were

irrelevant, since they reported what happened several years ago, not what

was going on today.

One of the indicators that I relied on was what was happening to urban

real estate. And, I had used a story which only partially appeared in

the paper and I want to share it with you.

A fellow next door to me, and I live on the wrong side of Dupont Circle

near the Cairo Hotel, bought his house for $42,000 in 1970. I bought

mine in 1963 for $29,000. He sold it in March 1978 for $177,000. The

guy who bought it came in to see me to ask if I could recommend a contractor because he needed three new bathrooms, a new kitchen, and a new

heating system. Last month, the contractor I recommended to him was in

my home on another matter and he said, "You know, that couple got into an

argument about what to do and they could not decide what to do," and I

said, "I know it." Because they did nothing, did not move into the house

8
and they decided instead to sell it, and they sold it last month for

$210,000. The Washington Post tells us there is not much of a movement

back to the city and I think that is a lot of 'hooey.' Because the rise

in urban real estate values in the last several years reversed a generationlong trend of a decline in those values and it seems to me that is the

most significant kind of indicator you can have that something is going on

in the cities.

Let me put all of this into some kind of perspective.

We have come to the end of, and through, a generation of relatively inexpensive and abundant new housing, mostly in new suburbs, in the generation

just past, with relatively low operating costs, reasonably low taxes, low

priced energy; the life-styles of most of our new households in that generation centered on that suburban way of life.

This has changed more rapidly than we realize. We are in a period of

rapidly escalating housing costs and prices, of rising operating costs and

property taxes, and a rediscovery of the potential of the city as a place

to live. We are learning the hard way that for many of today's and tomorrow's families, a larger share of their income than in the past generations will have to go to take care of their housing costs. We are also

moving into a period of intensified competition for living space.

Underlying much of what happens in these housing markets are the demographics of our society. This is indeed, a new demographic era. Population trends shift very slowly, almost glacierly, but like glaciers, they

are irresistible and they are dominant. The birthrate now is down. It is

down from 26 per thousand in the 1950 's to 14 per thousand—probably about

the lowest level we have had in the 200 years of our history.

In the first post-War decade, the population increased by 26 million, in

the 1960's it went down to an increase of only 21 million; this decade to

about 19 million, and it is staying about the same level.

Yet, with all the slowdown in the population increase, there is no decline

in the housing requirements. To the contrary, in the next 20 years we

face the largest bulge in housing that we have ever had. Anyway you look

at it, new household formation in the next 20 years will be the highest

in American history and the reason is very simple. Children born in the

post-War baby boom are now forming their own households, they need their

own housing. Taking the 30 year age group as a kind of entry age group

for forming households, for raising children and for making relatively

more permanent housing arrangements, you get some very interesting numbers

and they put the whole thing in the kind of perspective I was talking about.

From 1950 to 1955, 12 million people entered into the 30 plus age group

these were the kids born in the prosperity years of the 1920' s. From 1955

to 1960, 1960 to 1965, and 1965 to 1970, the numbers declined somewhat,

and this reflects the relatively low birthrate in the depression years.

From 1970 to 1975, something strange happens; it suddenly goes up to 14

million; 1975 to 1980 it goes to 18 million; 1980 to 1985 it goes up to

more than 20 million; and, 1985 to 1990 those numbers reach 22 million.
And, to the end of the century, the next two 5-year periods, they stay

at about 21 million or a bit less.

Now, compare this to the previous post-War peak of some 12 million and you

begin to see what is happening. New household formation in this period is

tending toward even higher rates than these 30 plus age group numbers

suggest. We are witnessing smaller and more numerous housing units, a

larger number of widows and widowers, who are incidentially living longer

and make of that what you will, live alone rather than with their families,

young people leave home, marry later and so the statistics suggest, also

live longer.

One of the changes is in life-styles—marriage as an early goal seems to be

losing favor. Life-styles are in flxix. Many of the new households are of

unrelated individuals—a nice way the Census Bureau has of saying, "They

ain't married."

However you express it, the wave of new home seeking households in the next

20 years is unbelievably greater than the public policy makers have been

suggesting. None of this is really a forecast of population, because all

of the people I have been talking about until the end of the century are

already born—they are already in-being.

There is a lot of debate about what kind of families there are going to

be, what their life-styles will be like. We know there will be smaller

families, we know they will have fewer if any dependents, they may be

putting their priorities differently than my generation did. The one certainty is change. We know they will be living under the inhibitions of

energy shortages, higher energy costs and with two working, they may not

fancy the long journey to work. What is likely is that in the next

fifteen to twenty years a lot of these people will come to live in the

central city.

In the first post-War generation, the low population in the 30 plus age

group generation, along with enormous economic growth of the U.S., not

only undergirdered the movement to the suburbs, but it lessened the

necessity to look to rehabilitation as a potent force in meeting our

housing requirements.

That period is now over. With the enormous number of shelter-seeking

families in the next two decades there are very serious questions as to

whether the Nation will produce enough new housing or whether it will

allocate sufficient resources and priorities to produce new housing to

meet the new demand.

This is one of the factors underlying the very rapid run-up of housing

costs and prices—a run-up which is going to be with us for a long time.

But, for this coming generation this really underlines and strengthens

the need to make better use of existing housing stock.

Today, the concept of where the housing frontier is located has changed.

In the first post-War period, that frontier was obviously in the suburbs.

Today's frontier is not only the suburbs, but must, of necessity, include

the central city.

10
One further comment about this. There is a myth that we have a city vs.

suburb confrontation. People looking at President Carter's urban policy

document were beginning to draw that conclusion from it. It is not

either/ or, or both. The other day in Denver, Jay Janus, the Under Secretary of the Department of Housing and Urban Development, said that

President Carter's new urban policy is not intended to stop expansion

outside the cities. He went on to say that the need is so great we must

make use of all the resources and we can no longer enjoy the luxury open

to us in the first post-War generation of neglecting the cities—we can

no longer afford to by-pass this enormous natural resource.

There is a back to the city movement! It may be in part the energy

crisis, a lot of young couples have what I would call a city preference;

it may be nostalgia; it may be in part a reaction to the centennial; it

may be that working wives are now experiencing what their husbands were

talking about when they talk of the journey to work and the trouble they

had; it may be that neighborhoods in urban areas have more life and vitality. I know that mine does. There was a Rabbi on one side, a rooming

house on the other. We have gays, winos, sikhs—sikhs are one of the

groups on my block and they own about five houses and there are a lot of

them. In fact, they have the only young kids on the block. There are

small shops, we have theives—I have been robbed but so have friends of

mine in the suburbs. The trash is collected twice a week. A lot of people

have nowhere else to go. There is a combination making for all of this

affluent, adventurous young couples, blue collar, middle income, ethnic

neighborhoods. The poor, crime, and unemployment are continuing and

serious problems. But, bear in mind what I said: every indicator shows

that city real estate values are going up and I think the Census statistics

about ten years from now will reflect what is going on now.

I found much going on in the cities that I visited and something equally

exciting is going on in other cities in America. The essential point is

that there is a "live in the city movement" plus a "back to the city movement" and that it is supported in large part by people who never left and

intend to stay. And, behind it all is the enormous pressure for housing

by the new families coming onto the scene.

There are a lot of problems. Some of the problems involve the housing

inventory itself and its rehabilitation. Older housing, built prior to

1940, was largely craft-built. A study by Miles Colean for the Twentieth

Century Fund, indicated that the typical builder in the 1930 's built about

one-half of a house a year—that is kind of an odd way to build I suppose.

This kind of housing may often require expensive customizing and modernization. From a cost standpoint, it puts limits on what you can do in

rehabilitation for lower income families, and mandates different methods

than are used in new construction. It is one of the reasons why builders,

suppliers, and trade unions have not yet mounted an effective low-cost

program for property rehabilitation. From a builder's standpoint, innercity rehabilitation is difficult; it requires more supervision, his overhead and administrative costs are much higher and there is no strong

11
pressure compelling him to work in the city. In addition, there are a

whole series of public constraints, ranging from land use subdivision

practices, to construction standards, to building codes, to income and

real property taxes.

In the course of my study I found a lot of cities, a lot of local governments, were not properly equipped to promote rehabilitation. They lack

local policy, they lack appropriate organization, and in almost all cases,

the whole process of regulatory standards—the clearances, the licenses,

the permits—discouraged both the entrepreneur and the home owner.

I saw a lot going on when I went out and I saw a lot of different kinds of

rehabilitation. I witnessed everything from a kind of cosmetic rehabilitation to a more complete restoration to make houses look as they did years

ago. I stress the concerns I have with the different types of housing

single-family vis-a-vis multi-family, because the building codes may affect

them in different ways. For example, it would be difficult to do any kind

of extensive rehabilitation in a multi-family building or structure without

adhering strictly to building regulations prevailing in the community. This

is so because the job is so large it does not escape the notice of the city

officials. Also, on a gut rehabilitation.

But there was a lot of rehabilitation going on as there was in one of my

neighbor's houses—all of it inside the house and all of it outside the

permit process. A lot of the rehabilitation that went on in the city was

of that kind and I do not think it is a very good way to do it.

I think it is obvious that strict adherence to building codes designed for

new construction would, in all too many cases, impede rehabilitation.

Violations often seem to occur in the building code standards in the jobs

when the occupants—frequently the owners—do a sizable amount of the work

themselves. The problem really arises out of the fact that we seem to

have no universally acceptable rehabilitation regulations which offer standards to which rehabilitation can be accomplished. Instead the rehabilitation, if major, in too many localities, is required strictly to conform to

whatever standard for new construction exists. In some cases involving

older structures, the question that I saw was, "Is it even possible to

meet the new construction standards?"

The problem relates to the extent of the rehabilitation. Take the case

of the new building code requiring stairways with certain height on the

risers, certain widths, certain depth and treads. When substantial rehabilitation does not really affect the stairwells and stairways, should the

stairways be reconstructed in order to conform to the new building code as

the 50 percent rule requires?

In no city that I visited did I see a separate code or separate provisions

for rehabilitation although I quickly found out there were different

standards, separate standards of enforcement and administration. For

example, in one city I was told the inspector looked at rehabilitation of

12
single-family jobs in terms of what was satisfactory at the time the house

was built. If no major question of public health or safety is involved,

building inspectors would overlook bringing everything in the house up to

the standard for new construction, even though more than 50 percent of the

value was being spent in rehabilitation.

Part of the problem I observed was differential levels of enforcement in

various areas and various neighborhoods. The building inspectors seem to

me to have a tendency to be a little less strict on single-family rehabilitation, particularly as I said, with the owner-occupant. Incident ially,

I think that when the problem is examined one of the things which needs to

be factored in is not only building code standards but the housing code

standards. There needs to be a reasonably close relationship between the

two. In some cases, and I venture to make this recommendation to you, you

may be thinking of a multi-tiered enforcement strategy which provides for

different approaches to satisfy different concerns between owner-occupied

and rental housing.

In summary, it seems to be important that we develop the key parts for a

model rehabilitation regulatory code, that these key parts be different,

maybe even less stringent than those for new construction, and that one of

the aims should be that they not impose extraordinary difficulties on rehabilitating older housing built in a different day to a different standard.

I would like to hasten to add the comment that in no way I am suggesting

that we lessen our concern for life safety and health features in whatever

regulations you people develop.

Inc ident ially , I am not recommending that we adopt a nationwide building

code—rehabilitation code—anymore that I would urge that we adopt a

nationwide building code. Rigid national codes, I think, can do a lot

of damage. We need to develop suggested performance standards for rehabilitation which could be reviewed by each locality, adjusted to meet local

conditions, and then coordinated with standards already in effect in that

community

.

In talking with building code officials, many of whom do think a separate

code is needed for building rehabilitation, I perceive that they, themselves were in effect, applying different standards of code enforcement to

rehabilitation than they were applying to new construction, particularly

rehabilitation in poorer neighborhoods.

In short, they themselves were applying their own wisdom which seemed to

me to be a separate kind of code treatment for rehabilitation because

they perceived the necessity to do so if they were, in fact, not to impede

rehabilitation beyond any hope of success.

It would be better, in my opinion, if the codes themselves provided such

authority or provided standards which gave such authority to building code

officials rather than relied on their willingness to use their own good

judgment.

13
There is a very serious question about what the Federal role in developing

building code and building regulatory devices ought to be. Without Federal

initiative and support, I have some real doubt that we will be able to

develop and put into widespread use any kind of model rehabilitation code

provisions. However, without State and local cooperation these code changes

will not have much acceptance. Therefore, it is important that it be a

tripod type effort along with the building code officials' organizations,

since they themselves are really the key to this sort of thing. Nothing

will work if it does not have their support and that support will not be

forthcoming without their involvement.

In our country, with its unique form of county and municipal governments,

there are thousands of code issuing and code enforcment bodies. Obviously,

neither the Federal government nor any single code organization can develop

code provisions until the States and the localities want to adopt. This

suggests the need for code utilization and implementation strategy which

brings these communities as I have suggested, into the code implementation

process and a strategy which also uses Federal benefits as a device for

getting these changes adopted.

There is something very exciting going on in many of our cities, more can

happen if we would choose the right path. Suggesting changes in building

regulation will not alone solve the rehabilitation problem. What we need

are good, sensible, model rehabilitation regulations, which allow the

communities to make locally practical variations and allow maximum discretion based upon performance standards. That is the challenge you are facing

and it is an important challenge and an important opportunity. Much depends

upon how you people, and the people whom you represent, move on the whole

field of revising the building code rehabilitation standards.

Much of the future of rehabilitation depends upon your work here. There

is no quick and easy answer to the whole business of revitalizing our cities.

When it happens, it is going to be done block-by-block, neighborhood-byneighborhood, by the people who live there and by other people who realize

it is good business and good government.

A scholar and a friend of mine, now in his 88th year, Nels Anderson,

still teaching at the University of New Brunswick in Canada (imagine teaching full-time at age 88), has just written a book on the Industrial Urban

Community. Apart from some very choice words on work, he has this salutory reminder—"Cities," he said, "since they first appeared, have been the

seedbeds for innovation and invention." "I cannot," he goes on, "run with

those who speak of cities in final decay. I prefer to believe that only

in the city, man's most ingenious invention, will we be able to meet the

challenges that threaten our civilization."

14
Overview off Massachusetts Pilot Project

by

Charles J. Dinezlo

Executive Director

Massachusetts State Building Code Commission

Mr. Dinezio is the Executive Director of

the Massachusetts State Building Code

Commission, where he is responsible for

the implementation of the Commission'

s

policies and objectives.

Immediately prior to this, he was the

Coordinator of Code Development in the

Massachusetts' Department of Community

Affairs where he was responsible for the

development of housing and building codes

for the Commonwealth of Massachusetts

.

In addition to other public employment,

Mr. Dinezio was involved in the private

construction sector as both a contractor

and home builder. He has lectured at various colleges and universities and provided consulting services to the National

Bureau of Standards, as well as several

universities

.

Mr. Dinezio is currently the President and

Northeast Regional Chairman of the National

Conference of States on Building Codes and

Standards, Inc., and serves on a number of

public and private professional committees.

The Massachusetts Building Rehabilitation Project, a unique public-private

action program involving the Commonwealth of Massachusetts and the nation's

major building code and research organizations, has been the outgrowth of

the growing concern that is being expressed throughout our country for the

need to more fully utilize and preserve our nation's building stock. This

concept is not new; Federal, State and local initiatives in this area

particularly with regard to housing—date back many years. The initial

impetus was based upon the goal of providing, for all citizens, housing

which met minimum standards of health and safety.

It is recognized that there are many forces at work which potentially impede

the full utilization of existing buildings; market forces, financial

consideration, income levels, industry structures, and regulatory activities

are but a few.

15
The National Conference of States on Building Codes and Standards (NCSBCS)

,

along with the model code organizations—Building Officials and Code

Administrators International, Inc., (BOCA), International Conference of

Building Officials (ICBO) , Southern Building Code Congress International,

Inc. (SBCCI)—and the Association of Major City Building Officials (AMCBO) , last winter concluded a study under contract to the National Bureau of

Standards (NBS) which sparked the Massachusetts Rehabilitation Project.

The results of that study indicated that building officials at the State

and local levels concur that there is a need to review their existing codes

relating to the issue of rehabilitation.

In conducting such a review, the weaknesses of the codes could be identified and a method for improvement initiated. Some specific problem areas

that were confirmed by the research sponsored by NBS fall into the following six major areas:

1. Codes represent new construction.

2. Requirements for complete code compliance are arbitrary

and may tend to increase costs.

3. The nature of current codes limits alternate solutions.

4.' Regulatory organization and procedures tend to be constraints.

5. Legal actions deter approval of alternate solutions.

6. Backgrounds and skills of code enforcement personnel are

diverse.

The nature of the problems noted above indicates that existing buildings

do require special treatment, if we are to achieve massive revitalization

and adaptive re-use of the existing building stock. The desired approach

to this problem is to develop a revised system of treating existing

buildings that ensures that the intent of codes is met for maximum protection of health and safety, while allowing flexibility in enforcement

and a sound technical basis for alternate solutions to meet safety standards.

In reviewing this NBS study, former Massachusetts' Governor Dukakis, and

the State Building Code Commission determined that our State could benefit

by a review of its existing building code and from the adoption of interim

building rehabilitation guidelines.

On March 4, 1978, Governor Dukakis invited representatives of eight major

national model building code and building research organizations to a

meeting in Boston to gain their assistance in developing an interim

building rehabilitation, code for our State.

Present at the meeting were representatives of BOCA, IGBO, SBCCI, AMCBO,

National Academy of Code Administration (NACA) , NBS, and NCSBCS. Governor

Dukakis outlined, for these representatives, a plan for undertaking the

Massachusetts rehabilitation project and pledged his personal support for

that effort.

16
Following discussion of the plan, the eight pledged together with the

Commonwealth of Massachusetts, a total of approximately $206,000 in cash

and in-kind services to the State building rehabilitation code project and

agreed to form a project team. The scope of the project called for NCSBCS,

as the prime contractor, to produce with the other members of the project

team, an interim code document containing code provisions for alterations

and additions to existing buildings. The code provisions are to establish

a system for the design professional, building owner, and State and local

enforcement officials to evaluate proposed changes to an existing building.

The format provides a structural and technical basis in place of current

ad hoc techniques. These model provisions have been included as elements

in a major revision to the Massachusetts State Building Code. These

provisions provide the enforcement official with guidelines for working

with the document, major technical issues which must be considered, and

alternate technical solutions and approaches which are applicable in the

State of Massachusetts.

In addition, the Massachusetts State Building Code Commission formed an

Advisory Council, comprised of representatives of interested and affected

parties in Massachusetts to review and provide constructive comments to the

draft provisions and guidelines throughout the project's development stages.

The final draft of the interim code provisions was completed by the

project team in August 1978 and was forwarded to the members of the State

Building Code Commission for their review and comment. These comments

were received by the project team and were incorporated into the

rehabilitation document.

In late September 1978, three one-day workshops were held in Massachusetts

for local building officials to explain the interim code provisions that had

been developed and to get their feedback for possible changes in the document.

Presenting the project to the local officials were representatives of the

State Building Code Commission and various members of the rehabilitation

project team.

17

Public Programs for Housing Rehabilitation

by

Anita Rechler

Neighborhood Conservation Specialist

U. S. Department of

Housing and Urban Development

Ms. Rechler received a Master's of Urban and

Regional Planning from the George Washington

University in 1974.

Prior to joining the HUD Office of Urban

Rehabilitation and Community Reinvestment,

her experience was in the area of community

development rehabilitation at the local level.

Ms. Rechler worked for the D.C. Department

of Housing and Community Development in the

program and policy development area. Some

projects included the development of guidelines for the D.C. Rehabilitation Loan Program;

development of Urban Homesteading Program;

and, operation of a demonstration program,

which provided small seed money grants to

neighborhood and non-profit organizations to

carry out innovative neighborhood preservation projects.

She worked with Ralph Nader on a two-year

project entitled, "What's Right with America,"

the results of which were published in the

book - Proudly We Hail.

Let me start out by telling you what I am not here to talk about. The

first thing I am not going to talk about is codes, the second thing is

HUD money and how you can get it for your cities, or your States, or even

for yourselves. Lastly, I am not going to talk about Section 511 of the

Housing and Community Development Amendments of 1978, which call for the

Secretary of HUD to develop model rehabilitation guidelines.

What I am here to discuss with you briefly are some of the HUD-funded

programs for housing rehabilitation, which you all will be living with

for the next few years.

I particularly want to talk about the programs administered through the

Office of Community Planning and Development. These programs are directed

by the former Baltimore City star of rehabilitation—Assistant Secretary

Robert Embrey. The programs are the Section 312 rehabilitation loan

19
program, the Coimnunity Development Block Grant rehabilitation projects,

the Urban Homestead Program, and the Rehabilitation Technical Assistance

Program.

Let me start with the Section 312 program. For those of you who are not

familiar with it, this is a direct Federal loan to property owners for

rehabilitation. Loans carry an interest rate of 3% for a maximum of 20

years. (Note: recent legislative changes permit the Secretary of HUD to

change the 3% rate depending upon the incomes of borrowers . ) The loan

limit for residential properties under the Section 312 program is $27,000

per unit for one and two unit dwellings. For non-residential properties

the maximum loan is $50,000. Priority for loans must be given to low and

moderate income families and loans are limited to specified neighborhoods.

Those of you who run Section 312 programs in your towns are probably

thoroughly frustrated with the on-again/of f-again funding cycle. You will

be pleased to know that the funding level for FY 79 will be $260 million,

a more than threefold increase over FY 78. In order to allow cities to

rationally plan their rehabilitation program HUD will be notifying cities

of their share of the available funds on an ongoing basis.

One of the things we will be able to do now that we have additional amounts

of money is to expand what has been an essentially single-family lending

program to include more multi-family and commercial properties. We are

authorized to spend up to $60 million for other than one unit rehabilitation.

We anticipate that these two "new" programs—the multi-family and the

commercial programs—will be a challenge to those of you who are in the

code business, since very few cities have been operating multi-family

rehabilitation or commercial rehabilitation projects.

The second activity that is administered by the Office of Community Planning

and Development is the Urban Homestead Program. This started out as a demonstration project and now is being expanded to cities throughout the country.

The program makes available HUD-owned property to localities. These properties are then turned over to persons who agree to rehabilitate them and to

live in the properties at least three years. The properties must be brought

up to health and safety standards before the property may be occupied, and

then within 18 months, must be brought up to a local code standard.

In addition to expanding the Homestead Program to an additional number of

cities, HUD will encourage the homesteading of multi-family properties. j Many of you have read about the multi-family urban homesteading that is

going on in the Bronx in New York City. It is being assisted through a

group called U-Hab—the Urban Homesteading Assistance Board. We hope to be

able to stimulate similar projects in other cities across the country where

there is a large stock of multi-family abandoned housing. We will do this

by providing technical assistance to implement multi-family homestead projects.

20
The Community Development Block Grant Program makes available monies to

cities on a formula basis. It allows communities wide discretion as to

how they choose to spend their money. Almost all the cities participating

in the program have chosen to use some of their money for rehabilitation.

Rehabilitation under the Block Grant Program is very diversified. Cities

have an opportunity to implement their programs almost anyway they want.

They can administer a program that is very closely tied to the rehabilitation codes and to code enforcement; they can choose to run a program

that is based upon very minimal standards of rehabilitation. Many communities also have provided a great deal of assistance to borrowers who

are participating in the program; others have chosen to do very little

work. HUD does not prescribe how the program shall be operated.

For code and building professionals, that means there is a great deal of

opportunity to participate in the development of a program; to work with

people who are running rehabilitation projects; and to talk about codes

and code enforcement and how to integrate that with the rehabilitation

that is taking place.

Partly because the Block Grant Program is so individualized, partly

because the level of rehabilitation activity has grown so quickly, and

partly because the supply of well trained, highly-skilled people at the

local level has not kept up with the pace of rehabilitation, we have started

a Rehabilitation Technical Assistance Program that operates through the HUD

Central Office. The technical assistance program has been doing two things.

First, we have been working to establish a Housing Rehabilitation Training

Program. This will be a training institute which provides courses on an

ongoing basis in the field of urban rehabilitation. At a minimum, courses

will be available in the following subject areas:

rehabilitation construction;

rehabilitation program design and administration;

rehabilitation management; and,

rehabilitation finance.

We will be training the staff of local government agencies, non-profit

housing groups, neighborhood organizations, and others engaged in rehabilitation activities. The courses will be designed to teach rehabilitation

professionals the various "nuts and bolts" skills required to carry out

their programs.

The second part of our technical assistance activity is direct outreach

to cities through workshops and publications. We are publishing several

guidebooks on rehabilitation program finance and administration. These

guides are used as the resource material for various workshops and seminars

for rehabilitation professionals.

21

HUD Rehabilitation Guidelines

by

Robert J. Kapsch

Program Manager

Rehabilitation Guidelines Activities

U.S. Department of Housing and Urban Development

Mr. Kapsch earned a B.S. in Engineering

from Rutgers University in 1964; a M.S.

in Management of R&D from George Washington University in 1974; and, a M.A.

in American Studies from George Washington University in 1978.

Mr. Kapsch joined the staff of the Center for Building Technology in 1971. He

has held various management positions

of research activities aimed at developing the necessary technical basis for

governmental regulations for buildings

and communities. He is currently on

detail to the U.S. Department of Housing

and Urban Development, to assist in the

development of rehabilitation guidelines.

Prior to coming to the Center for Building Technology, Mr. Kapsch was employed

by the Air Force Data Systems Design

Center where he was a manager of computer

specialists engaged in developing new

computer systems for the Air Force medical

services, by the Central Intelligence Agency

where he was a project engineer , and with

the Air Force Surgeon General's Office as

a Medical Construction Officer.

It is a pleasure to be here.

I am the HUD Departmental Representative on the Rehabilitation Guidelines.

Two weeks ago Congress, in its 32-hour marathon session prior to recess,

passed the Housing and Community Development Amendments of 1978. Included

in that Bill is a Section on rehabilitation guidelines. I would like to

talk to you today on where that provision on rehabilitation guidelines

came from, where it is now, and what it directs HUD to do.

As Jim Gross mentioned, I first became interested in the subject of

rehabilitation and building codes back in 197 5 when I was his Assistant

Chief. I wrote several papers on the subject and worked on a number of

the publications that are on the table outside.

23
When I received the American Political Science Association's Congressional

Fellowship, I was asked to join Senator Proxmire's staff on the Banking,

Housing and Urban Affairs Committee, specifically for the purpose of

organizing a hearing of the Committee, chaired by Senator Proxmire, on

the problem of building codes and rehabilitation.

There are a number of reasons for Senator Proxmire's interest in this subject,,

First, he has always been an admirer of the late Senator Paul Douglas. As

a matter of fact, a number of Senator Proxmire's staffers used to work for

Senator Douglas. In addition, Senator Douglas was, of course, the Chairman

of the Douglas Commission, which studied among other things, building codes.

One of the recommendations made in 1968 from the Douglas Commission was

that Congress authorize the Secretary of the Department of Housing and

Urban Development to develop model standards to be incorporated into local

building codes with special reference to the needs of rehabilitation of

housing. This recommendation was never acted on.

The hearing by the Senate Banking Committee on building codes and rehabilitation was held on March 24, 1978. The record of the hearing has just

been published, about one month ago. Copies of the record of this hearing

are available from the Senate Banking Committee, 5300 Dirkson Senate Office

Building, Washington, D,C.

A number of the speakers that you have heard or will hear today provided

testimony at that hearing. These include Tad Stahl, Charles Dinezio and

Nat Rogg,

In addition to the witnesses at the hearing, written testimony was solicited

from each major organization in the building community, such as the Chamber

of Commerce, National Association of Home Builders, National Fire Protection

Association, American Institute of Architects, and others. Not all chose

to provide written testimony for this hearing, but many did and those are

included in the hearing record.

Senator Proxmire had four questions for the witnesses at this hearing:

1, Do building codes and other regulations obstruct or discourage

rehabilitation, particularly Federally-assisted rehabilitation?

2, Should a model rehabilitation code or standard be developed for

the use by States and communities in regulating rehabilitation?

3, If so, by whom? Who should do the work to develop such a model

rehabilitation code or standard?

4, Since the regulation of rehabilitation is primarily a State

responsibility, what is the appropriate role of the Federal

government, if any, in developing and implementing such a

model rehabilitation code or standard?

24
The answers to these four questions that Senator Proxmire received were:

First, on whether building codes do provide a problem or obstruction

to rehabilitation was, "Yes, it was a problem." Virtually all the

testimony received indicated that building codes do have an adverse

impact on housing rehabilitation. Some of the testimony indicated

that funds wasted on rehabilitation due to unnecessary building code

requirements was as much as 20% of the total rehabilitation budget

leading Senator Proxmire to later state that perhaps as much as $240

million a year of Federal funds may be wasted through this source.

On the second question—Should a model rehabilitation code or standard

be developed?—there was little agreement on what should be done. Some

held that a model rehabilitation code should be developed, others said

it should be a standard, or it should be rehabilitation guidelines.

On the third question—Who should develop such a code or standard?

there was even less agreement. Organizations mentioned include the

National Institute of Building Sciences (NIBS), National Conference

of States on Building Codes and Standards (NCSBCS), National Bureau

of Standards (NBS), model code organizations and others.

But, on the fourth and final question—^What is the role of the

Federal government, if any?—there was substantial agreement, both

on the written and the oral testimony received by the Committee.

The testimony indicated that the Federal role with respect to

building codes and rehabilitation should be limited to funding the

necessary effort. Further, there was a substantial agreement that

whatever should be developed - rehabilitation standard, guidelines

or codes - should be developed by the private sector with Federal

support.

There was also a consensus in the testimony that no sanction should be

imposed, such as the withholding of Community Development Block Grant funds,

on the States and communities to encourage them to adopt any rehabilitation

standard, guidelines or code that might be developed.

With this background. Senator Proxmire decided to offer an amendment to

the Housing Authorizati on Bill, directing HUD to develop rehabilitation

guidelines.

This amendment was offered on the Senate floor on April 26 by Senator

Proxmire. The provision directed the Secretary of HUD to develop model

1 rehabilitation guidelines for the voluntary adoption by States and communities, to be used in conjunction with the existing building codes by

State and local officials in the inspection and approval of rehabilitated

i properties.

25
Second, it Instructed HUD that such guidelines shall be developed in

consultation with the National Institute of Building Sciences, appropriate

national organizations, officials of State and local governments, representatives of the building industry, consumer groups, and other interested

parties.

Third, it directed the Secretary of HUD to publish such guidelines for

public comment not later than one year after the date of enactment of

this Section and promulgate them no later than 18 months after such date

of enactment.

Fourth, it directed the Secretary of HUD to furnish technical assistance

to State and local governments to facilitate the use and implementation

of such rehabilitation guidelines.

Finally, it directed the Secretary of HUD to report to Congress, not later

than 36 months after the date of enactment of this Section regarding:

(1) actions taken by State and local governments to adopt guidelines or

equivalent; and, (2) recommendations for further action.

During the Senate markup of this Housing Bill, HUD neither supported nor

opposed this amendment and it was included in the Senate version of the

Housing Authorization Act. However, the Proxmire amendment was not

included in the House version of the Housing Authorization Act, and it,

therefore, went to the Senate-House Conference. This is the Conference that

had been reconciling the differences between the Senate version and the

House version of the Housing Authorization Bill.

Toward the end of the Conference, the House receded to the Senate position

on the rehabilitation guidelines provision. The only change that was made

by the Conference was that the statement the Secretary "shall" furnish

technical assistance in implementing the rehabilitation guidelines was

changed to the Secretary "may" furnish technical assistance.

While this was going on, on August 11th, the Under Secretary of HUD,

Jay Janis, sent a letter to the Director of NBS requesting that I be

detailed to HUD for a period of six months to assist HUD in the development

of the model rehabilitation guidelines.

The current status of this provision and this Bill is that we expect the

President to sign the Bill in the very near future.

In implementing this provision, the first decision HUD has to make is in

which HUD component this activity should fit. There are a niomber of

components that are very intimately involved in rehabilitation: Community

Planning and Development, headed by Assistant Secretary Robert Embry; and,

as Anita mentioned, this is the HUD component which administers the

community development block grant programs, the Section 312 rehabilitation

loan program and other rehabilitation activities. It could also go under
Housing, headed by Assistant Secretary Lawrence Simons, which has the very

large Section 8 substantial rehabilitation and moderate rehabilitation

programs. Or, it could go under the Policy Development and Research

component, headed by Assistant Secretary Donna Shalala, We expect that

this decision will be made within the next day or two by the Under Secretary,

Once the major component has been decided by the Under Secretary, it will

be possible to move forward on the other decisions relating to developing

the rehabilitation guidelines such as the budget level, the conceptual

approach and the contractors to be used, I say contractors because the

intention here is not to use in-house HUD staff for this effort. This

effort is intended to be developed by the building community, funded by

the Federal government.

No doubt many of you will become involved in this effort in the next coming

months. We are certainly looking forward to the interaction and the

technical expertise that you can bring to bear in assisting in the development

of these rehabilitation guidelines.

27
Questions

QUESTION ; Unidentified Participant

Would you please comment on the relationship between rehabilitation standards and the Minimum Property Standards (MPS), and

HUD insurance programs for rehabilitation?

RESPONSE ; Robert J. Kapsch

The hearings covered both conditions of participation such as

the MPS's and other regulations, like the 312 regulations and

block grant programs. They also questioned State and local

building codes. Testimony was mixed on what was the real problem. Some of those giving testimony said the real problem was

the MPS's and not State and local building codes. Probably the

bulk of the testimony leaned the other way. That is one of the

problems in this area; there is very little objective evidence.

There is a lot of expert opinion that has been provided but very

little objective evidence as to which document is the specific

problem and what specific problems are involved in each of

those documents.

QUESTION ; Unidentified Participant

Is the intent to relax the MPS's as a result of this?

RESPONSE ; Robert J. Kapsch

This provision has nothing to do with any HUD condition of

participation regulation currently issued by the Department.

It is an extramural effort.

QUESTION ; Richard Kuchnicki, National Association of Home Builders

You said that these guidelines will be re-evaluated in 36

months to determine what action is necessary if they are not

being implemented. Does that mean that 36 months from now they

could become a Federal standard if HUD is not happy that they

are not being used?

RESPONSE ; Robert J. Kapsch

I do not think that is the intention that they become a Federal

regulation. The intent was to answer the question of sanctions.

Senator Proxmire's primary interest in rehabilitation guidelines

was Federal funds wasted. We are going through a period where

Federal expenditures for rehabilitation programs are astronomically expanding. This is true in the Housing Amendments of 1978

and he is very concerned on the issue of sanctions. That

provision—the 36 month provision—is primarily addressed to

whether sanctions should be imposed and that is different than

a Federal regulation.

28
Session on Code Provisions and Their Impact

Moderator: T. H. "Nick" Carter, Former Executive Director

International Conference of Building Officials

Richard Kuchnicki

Associate Director,

Technical Services

National Association of

Home Builders

Paul Folkins

Principal Structural

and Safety Engineer

City of Boston Building

Department

Kenneth M. Schoonover

Chief Engineer, Codes

Development and

Interpretations Div.

BOCA International, Inc.

29

SESSION MODERATOR

T. H."Nick" Carter

Former Executive Director

International Conference of Building Officials

Mr. Carter earned a B.S. in Civil Engineering from the California Institute of

Technology . Prior to joining the staff of ICBO in 1958,

he was senior structural and research engineer for the City of Los Angeles Building

and Safety Department. He became Executive

Director of ICBO in 1962.

Mr. Carter was instrumental in the development of the One and Two Family Dwelling Code,

was a HUD contractor in preparing a report

for the Douglas Commission on the building

code situation in the U.S., was secretariat

to the Model Code Standardization Council, and

held a position on the Advisory Council for

the Development of Operation BREAKTHROUGH.

Mr. Carter recently opened a private consulting

practice and has been retained by the Council of

American Building Officials for technical coordination under the CABO / DoE contract to develop

model solar energy documents.

He is a member of numerous national boards and

his professional affiliations include the

American Concrete Institute and the National

Fire Protection Association, among others.

All of us in the code enforcement field have been aware for years that

problems exist with the national model codes in regard to rehabilitation

of buildings. The problem is created by those provisions in the codes that

relate to alterations or additions to existing buildings. These provisions

are often referred to as the 50% rule and require that if a building is

altered or rehabilitated by more than 50% of its replacement value the

entire structure must comply with the requirements for a new building.

Strict application of the 50% rule can and often does result in unreasonable

enforcement policies in regard to existing buildings. As examples, an

existing building may have 8% of its floor area in window area as compared

to the code requirement of not less than 10%; or where the code requires

an 8-foot high ceiling, a 7-foot ceiling would create a non-conforming

31
building. We all realize that these are not serious health violations but

if the code is strictly enforced, it means that alterations cannot be made

to the building unless the entire building conforms to the code requirements

for a new structure.

We believe that the original purpose of the 50% rule was to prevent

alterations to existing non-conforming buildings where it would prolong

their life and create a hazardous condition.

The 50% rule has been used for many years and often as a vehicle to demolish

non-conforming buildings in blighted areas. In other words, it was called

a rehabilitation program but in fact was a demolition program which did away

with many structures that had many years of serviceable life still remaining.

Based upon these experiences, code enforcement officials now realize that a

new tact must be taken to maintain our existing housing that does not present

a hazard to life or limb.

The code enforcement officials want and need an enforceable rehabilitation

code. Not having it creates a serious legal problem for the officials,

particularly due to repercussions because of sub-standard construction that

results in the loss of life.

We believe that in order to provide a vehicle to the building official to

allow rehabilitation and to ease his legal responsibility, that it is

necessary to develop a set of guidelines or a manual of practice for rehabilitation of existing buildings. It will give us the alternates that are

necessary to do an effective job at the grass roots level.

32
Application of Article 22 of the Massachusetts State Building Code

by

Paul Folkins

Principal Structural and Safety Engineer

City of Boston Building Department

Mr. Folkins is a Civil Engineering Graduate of Lowell Technological Institute.

Mr. Folkins joined the staff of the City

of Boston Engineering Department in 1964.

Since that timer he has served in several

capacities , including Senior Engineering

Aide and Senior Structural and Safety Engineer. Currently, he is Principal Structural

and Safety Engineer, and provides consultant

services to architects, engineers, and contractors on the Massachusetts State Building

Code, as well as other State, Federal and

national codes and regulations.

Prior to joining the Engineering Department,

he served as Senior Engineering Aide-M.C .D .- Parks Engineering Department; Assistant Resident Engineer and Chief of Survey, Barnes

Engineering; and. Student Trainee, U.S. Army

Corps of Engineers.

I am going to give a specific example of a building that was rehabilitated

and re-used in the City of Boston, imder the current Massachusetts State

Building Code. This will include the problems encountered in obtaining a

building permit, and the sections of the Code that the building, in theory,

violated. I will then go through the process as it would be looked at

under the proposed Article 22 of the Massachusetts State Building Code

entitled, "Repair, Alteration, Additions and Change of Use of Existing

Buildings."

33
The structure in question is a warehouse building, built around 1870.

It is five stories high, heavy mill construction, type 3A, 62 feet to the

highest point of the roof, and its legal occupancy is listed as merchantile.

It is a rectangular structure, 25 feet wide and 60 feet deep, with an

area of 1500 square feet per floor.

Since its inception, the building had been used as a warehouse, merchantile

building. For the year prior to its renovation it had been vacant and

open to trespass. It had been included with a whole series of almost identical buildings in a massive rehabilitation program.

The proposal to change the occupancy of the building was brought before the

City of Boston Building Department. It was proposed to change the use to

five apartments. The whole area where it is located is being changed from

merchantile to residential occupancy.

The floor plans, as presented to the Department, are shown in Figure 1.

The basement, which was almost completely below grade, was going to be

used for the boiler room and possibly, a storage area. There would be a

one-bedroom apartment on the first floor and one, two-bedroom apartment on

each of the remaining four floors. This total gutting of the building is

a very typical rehabilitation situation for the City of Boston.

The building, when evaluated under the present Massachusetts State Building Code, had an assessed value of $10,000. If looked at strictly as a

replacement, it would cost approximately $60,000 to replace the shell of

the building. The proposed work would cost approximately $100,000. The

amount of work, therefore exceeded 50% of the assessed value of the

building. In fact, it was over 100%. Therefore, the Code mandated that

the building be brought up to requirements for new construction in all

respects.

This entailed a rather lengthy appeal to the State Building Code Commission for every building under consideration. Approximately 30 buildings were being renovated, and individual appeals had to be filed for

each and every one of them, even though the problems were very similar in

each building.

The Sections of the Massachusetts State Building Code, which is based on

the BOCA Basic Building Code, which were appealed are:

• Section 303.0 - Buildings of type 3A construction are not

allowed over four stories, 50 feet high. The existing

building is five stories, 62 feet high.

• Section 616.21 - All interior stairs shall be 42 inches in

width. It was proposed to re-use the old stairwell opening,

thereby reducing the width of the stairs to 36 inches.

34
• Section 616.62 - All stairway doors shall swing onto the

stair landing in the direction of egress travel. The doors

off the stairway are proposed to swing into the apartments

not onto the landing.

• Section 616.9 - The stairway shall be of non-combustible construction and have a two-hour fire resistive enclosure if over

3 stories high. The proposed stairway is of wood construction

with a two-hour combustible fire resistive enclosure.

• Section 621.0 - All windows on or within 5 feet of fire balconies shall be fire windows (wire glass in steel frames)

.

The proposed windows are plain glass in wood frames.

• Section 718.0 - The existing building was not designed for

seismic forces.

• Section 815.0 - The existing mortar (lime) does not meet the

requirements for new mortar.

• Section 868.0 - All masonry exterior walls shall have parapet

walls 2 feet above the roof. The existing parapet walls are

1 foot above the roof.

• Section 1206.0 - Standpipes are required in buildings of residential occupancy over 3 stories high. It was proposed to omit

the standpipes.

This project went to the Board of Appeals, which granted all variances,

the building permit was issued and the building was rehabilitated under

a Federally-assisted program and is currently being occupied.

Under the proposed Article 22, the building official would look at the

existing building and proposed changes to determine if any hazardous

conditions exist and if the hazard level index is being increased, decreased or staying the same.

In the example, the existing building is structually sound and has two

means of egress (the stair and the connecting balconies); therefore, no

hazardous conditions exist. The hazard index number of the existing

merchantile occupancy is 3 and of the proposed residential occupancy is

2; therefore, the hazard level is being decreased and under Section

2203.8.1 of Article 22, no further compliance with the Code is required

except for new systems—plutnbing, electrical, HVAC—partitions, the

new stairway and the fire alarm system.

By having no hazardous conditions and decreasing the hazard index, the

violations under Sections 303.0, 621.0, 718.0, 815.0, 868.0, and 1206.0

do not occur as no compliance with those sections is required.

35
However, as a new stairwell is being installed, Sections 616.21, 616.62

and 616.9 must be complied with as per Section 2203.8.1.1 of Article 22.

Section 2203.8.1.1 allows compliance alternatives and therefore, the

building official can allow less than total compliance with the code for

new construction.

Sections 616.21, 616.62 and 616.9 require that the stairway be 42 inches

in width, have doors swinging onto the landings and be of non-combustible

construction with a two-hour fire resistive enclosure. The proposed

stairway is 36 inches in width, has doors that swing into the apartments,

is made of wood, and is enclosed with two-hour combustible fire resistive

partitions (2 layers of 5/8 inch gypsum wallboard, type X, both sides of

wood studs).

A stair of 36 inches in width is one and one-half units of egress width,

which gives an allowable occupancy of 113 persons per floor. The occupancy load allowed in the previous merchantile occupancy is 25 persons

per floor and under the proposed residential occupancy is 6 persons per

floor. Therefore, a 36 inch stair is more than adequate for the occupancy

load, as it is unlikely that 113 persons are going to be in the entire

building, let alone on any one floor. Furthermore, to install a 42 inch

stair the floor would have to be restructured and reframed, reducing the

size of the apartment units and possibly, rionning into structural problems*

A friend of mine, who is a structural engineer has a saying that, "Buildings that are together, tend to stay together if you don't disturb them."

This is true, it is best to do the least amount of structural work as is

possible if the building is structurally sound.

The requirement for the swing of a door onto the stairwell landing was

written from the point of view of a larger structure in which a corridor

leads to the stairwell. Therefore, you would want the door from the

corridor to the stairwell to swing onto the landing in the direction of

egress travel. Historically, in row buildings which were used as apartment houses and/or lodging houses, the doors have always swung into the

units without endangering the life safety of the occupants.

The existing stairs were wood with an unrated enclosure. The proposed

stairs would be wood with a rated enclosure. Due to the various floorto-ceiling heights, as well as other construction difficulties, steel

stairs were not chosen to be used.

Because of the previous statements and the fact that the occupancy safety

of the building is being increased via the use of fire retardant finishes,

installation of a fire alarm system, and the rated enclosure of the

stairwell, the building official could approve the permit without requiring a Board of Appeal hearing.

This is only one small example, and the principles illustrated could be

used in many other circumstances.

36
37

Impact of New Construction Oriented Codes on Building Rehabilitation

by

Richard P. Kuchnicki

Associate Director of Technical Services

National Association of Home Builders

Mr. Kuchnicki received a degree in architecture from Texas A&M University.

After several years as an officer with the

U.S. Army Corps of Engineers where he served

as a construction engineer in various assignments in the U.S. and overseas, he joined

the staff of the National Association of Home

Builders (NAHB) . Currently, Mr. Kuchnicki is

the Associate Director of Technical Services

with NAHB, where he is involved in providing

service and advice to builders in such areas

as codes and standards, energy conservation,

and materials and building systems. In addition, he has represented NAHB at model code

revision hearings and on various committees

of these groups. Mr. Kuchnicki is the staff

coordinator for NAHB's Special Committee on

Energy

.

Mr. Kuchnicki is co-author of the "NAHB Builders Guide to Energy Conservation" and assisted

in the development of the NAHB Thermal Performance Guidelines for One- and Two-Family

Dwellings , and Thermal Performance Guidelines

for Apartments and Condominiums. In addition,

he serves on several committees of the National

Fire Protection Association and the American

Society for Testing and Materials.

Mr. Carter mentioned that I have been involved somewhat in energy

conservation matters with the National Association of Home Builders

(NAHB). However, one of the biggest jobs in my department is in the

area of codes and standards. When Nat Rogg left, our membership was

up to 85,000; we now have over 108,000 members in NAHB and we are

expanding our services to our members. One of the big areas that we

are expanding services in is in the area of remodeling and rehabilitation. In the back of the room is the Assistant Director of the NAHB

Remodeling and Rehabilitation Department, Amy Van Doren. So, if there

are any questions I cannot answer. Amy is here for you to talk to and

answer questions.

My comments will be directed more toward the builders concern about

those items in the code that affect rehabilitation because of the fact

it is part of a new construction type code. It would have been good if

39
we had a copy of the Massachusetts Rehabilitation Code ahead of time to

to critique. However, I am sure we will be putting our comments together

and sending them to the gentlemen who put it together.

NAHB shares the concern of many others that building codes can present a

nearly insurmountable barrier to rehabilitation projects, particularly

when enforcement officials insist that the whole structure be brought up

to new construction standards.

The fact that the model building codes require an existing structure be

brought completely up to the standards of the currently enforced building codes whenever rehabilitation costs exceed 50% of the building's

value and in some instances require all new work to comply where costs

are between 25-50%, creates real problems for builders who want to

undertake a rehabilitation project.

The low property value of many of the older buildings compounds the

problem even further when the 50% rule is applied. In many cases, older

buildings cannot be brought up to standards of the model building codes

because these codes are new construction oriented. Many obsolete

construction materials and techniques are not addressed in the codes

because they have been replaced by new technologies.

The prescriptive language iti new construction oriented codes can create

problems that are unique to existing buildings. The truly performance

type code for rehabilitation is, therefore, of prime importance.

Another problem which can make a rehabilitation project difficult is

the lack of coordination among the various codes—building, plumbing,

mechanical and electrical. Right now we are just addressing the building code here. While the three model code groups all have their own

building code, mechanical code, and plumbing code now that ICBO has

recently adopted a plumbing code, there is still little or no

coordination with the National Electrical Code (NEC).

For example, although the building code is supposed to be concerned with

fire ratings of construction assemblies and combustibles in concealed

spaces, the NEC has been trying to regulate the use of non-metallic

sheath cable based on the argument that it is a fire hazard. The same

problem has existed with plastic pipe requirements in the Uniform

Plumbing Code.

Bringing older buildings completely up to the standards of a currently'

enforced building code is even further complicated by the fact that

there are now many ne^w sections in the code that did not exist when the

building was constructed and are not imminent hazards to life and

safety. The reason for this is that in recent years there seems to be

a trend toward the use of building codes to regulate the social problems

of our nation.

40
One example of this is the provisions for energy conservation, NAHB has

been a strong supporter of energy conservation in buildings. However,

these measures must be cost-effective and realize a payback to the

consumer within a reasonable time period. The energy conservation

measures currently in the model codes are, in some instances, not even

cost-effective for new construction. They certainly will not be

cost-effective for a rehabilitation project.

Another social problem that is beginning to be addressed in the building

codes is that of building security. It has been our position that

security measures do not belong in a building code and they certainly

should not be part of a rehabilitation code.

Barrier free design is yet another area that the building code now

addresses. Certainly the problems of making the building accessible to

the handicapped are much different in an existing building than they are

in new construction.

Sound transmission control is yet another new addition to the codes in

recent years which is not a life safety issue.

These non-life safety type of items should definitely not be included as

requirements in a rehabilitation code. Perhaps, they could be separated

and put into some form of guidelines to consider depending on what the

local needs are as far as, for example, barrier free design is concerned.

Another area of concern we have is the fact that most buildings have

been constructed using the concept of fire-zoning or fire districting,

where it was the intent to limit construction and uses of buildings so

that fire would not spread from building to building over a large area

of a city.

Highly concentrated built-up areas where the greatest possibility of

conflagration exists would be in a more restrictive fire zone. As it

turned out, however, establishing the fire zones did little to limit

conflagration, since the application of fire zones for new construction

did little to change the condition of existing buildings and such zoning

is usually not applied until its needs can be justified.

In recent years, there has been much discussion at the hearings of the

model code groups concerning the elimination of the fire zoning concepts

from the code, because it is not effective and in many cases it is not

being enforced.

NAHB has supported the proposals to delete fire zones, not only because

they have not been effective but also because they have been a detrimental effect on the rehabilitation of older buildings, since rehabilitation is not often feasible due to more restrictive requirements which

occur within the fire zones.

41
These problems that I have mentioned are only a few of the constraints

which are placed on rehabilitation by building codes which are new

construction oriented. Whether or not the preparation of a code which

specifically addresses the rehabilitation of buildings can solve these

problems will depend on many factors.

One of the biggest factors which will affect the successful development

of a rehabilitation code is whether or not a truly performance type code

can be developed which can be easily and practically interpreted.

Materials and construction standards must be written in performance

terminology by stating clearly "what" is to be achieved, rather than

"how" it is to be achieved.

Uniformity of code requirements, as well as uniform enforcement

requirements, are essential. The model code groups will have to work as

a team in developing one, single, uniform code.

It will be very important to utilize the knowledge and skills of all

those organizations and individuals which have experience in code

development and enforcement and those which must comply with the codes.

NAHB strongly urges that a committee structure be set-up similar to the

Council of American Building Officials' One- and Two-Family Dwelling

Code Committee, which has a wide representation.

Currently, the code revision committees of the model code groups include

code enforcement personnel only. We feel strongly that a rehabilitation

code committee should also include builders, architects, engineers,

consumers, labor representatives and other affected groups.

An effective training and education program will be necessary to

properly implement the code. This program should be directed not only

toward building officials, but also to builders, architects, engineers,

etc. NAHB stands ready to assist in such a program.

In summary, NAHB's viewpoint as far as the impact of building codes on

rehabilitation is concerned, is that although rehabilitation remains an

excellent source of lower cost housing, improperly written codes can

destroy this source. When rehabilitation means gutting, then we have

turned rehabilitation into new construction.

It is, therefore, extremely important that a rehabilitation code be

written which is truly performance oriented and concerns itself with

those items only that affect the health and safety of the building

occupant.

42
Code Requirements for Existing Buildings: A New Approacli

by

Kenneth M. Schoonover

Chief Engineer

Building Officials and Code Administrators International, Inc.

Mr. Schoonover received a B.S. from the

Milwaukee School of Engineering in 1973.

Currently, Mr. Schoonover is the senior

staff engineer of the Building Officials

and Code Administrators International, Inc.

(BOCA), where his responsibilities include

code interpretation, code development and

general technical services. In addition,

he is the project director of the National

Conference of States on Building Codes and

Standards-Department of Energy, Energy

Code Contract and will be involved in BOCA'

s

continuing activities in the energy conservation, rehabilitation and related code

development areas.

Mr. Schoonover 's teaching assignments have

included Building Code, One- and Two-Family

Dwelling Code, and Plan Review Workshops,

as well as several short courses in energy

conservation. He is a registered Professional

Engineer in the State of Wisconsin and is

listed in the Directory of Fire Research

Specialists published by the National Bureau

of Standards

.

It is a pleasure for me to be here today because of my close involvement

with this project. I have been called a specialist on this subject but

that is probably only because this project has involved trying to do

something with the current codes that has never been done before; that

is, attempting to change how the building code is applied to existing

buildings.

Whenever something new like this is attempted, we tend to tread new

ground, try to solve some old problems, but this often brings up some

new problems. In this respect, this effort has been particularly

challenging. We think we have taken what is the first step in trying

to improve the codes as they relate to existing buildings.

The document I am referring to represents an effort at trying to improve

the existing building code provisions for the State of Massachusetts.

The project was conducted specifically for that State and, therefore,

43
some of what Is contained in the provisions reflects or represents some

State-specific concerns. Rather than go into specific detail as to what

is contained in this document, I would like to address the concepts or

objectives which were outlined and identified and which we intended to

establish by the specific code provisions.

The State of Massachusetts is adopting the 1978 BOCA Basic Building Code

as its statewide code. The Basic Building Code contains, which has been

mentioned previously, rules for the application of the code to existing

buildings and is commonly referred to as the "twenty-five - fifty

percent" (25-50%) rule. These rules relate to the cost of alterations

or repairs compared to the replacement value of the building and

establish what is now identified as rather arbitrary triggering

mechanisms for code compliance.

To what extent must existing buildings currently comply with the code

for new construction? Very simply, if the cost of alterations or

repairs is less than 25% of the value of the building, those alterations

or repairs may occur with no further compliance to the code for new

construction; that is, they may be replaced with what was originally

there. This aspect of the 25-50% rule has posed no significant problems.

If the cost of alterations or repairs exceeds 50% of the value of the

building, the code specifically says that the building must comply with

the code provisions for new construction, irrespective of the condition

the building is in. The existing conditions may or may not be easy to

make comply with the code for new construction. Although this causes

many compliance problems for the owner of the building, this aspect of

the rule has been easy to enforce. The building must comply with the

code, no ifs, ands, or buts about it.

The last range of the current 25-50% rule left to discuss is the aspect

which many code enforcement officials find troublesome. If the cost of

alterations or repairs is between 25 and 50% of the value of the building, the code states that the building official shall determine to what

extent that building shall comply with the code for new construction.

It is up to the building official to specify the level of compliance

which will result in an acceptable building for re-use. This aspect of

the rule opens the door for decision-making, judgmental decisions about

the proposed alterations and, in general, exactly what the building

official will accept in terms of minimum requirements.

The essence of the provisions drafted for the Massachusetts State

Building Code are an expansion of the range of the current 25-50% rule

under which the building official determines to what extent the building

shall comply. It is intended to expand the decision-making ability to

any situation when alterations or repairs are being made and does not

arbitrarily specify that either the entire code for new construction

shall be complied with or that no new compliance shall be required. It

is anticipated, under this expansion of the decision-making ability for

44
the building official, that he will work hand-in-hand with the building

owner and/or architect to come to agreement on the conditions which will

be permitted to occur in the re-use of existing buildings. By removing

the arbitrary triggering mechanisms we hope we will have removed the

primary obstacle to the rehabilitation of existing buildings.

This concept states as simply as possible that you can do anything in

building in terms of alterations or repairs which improves its condition

or basic level of compliance to the current code for new construction.

You can do nothing to reduce its level of compliance. With the

exception of certain changes in use group, and the installation of new

construction systems, at no point will one have to face the possibility

of the code indicating that full compliance for new construction is

required.

This poses a unique challenge since every given existing building has

individual and unique sets of circumstances. Under this concept, one

must evaluate the building as it exists and has been previously

operating. Every existing building will fall at a certain point in

terms of its reference to compliance with the code for new construction.

The code establishes requirements for all new construction, therefore, a

building may be evaluated in terms of what degree it presently complies

with the code for new construction, and this should be fairly easy to

measure. At the other end of the measuring stick, a code outlines what

is termed an unsafe or dangerous building. Although it is not very

explicit on all unsafe conditions, it does establish that this is the

bottom line of the code in terms of life safety. The code does not

permit a building to exist in an unsafe condition.

Having these two reference points, all existing buildings will fall in

this range usually between the point of unsafe and complying with the

code for new construction. Most buildings, I expect, fall somewhere

below the level of the code for new construction; that is, they do not

fully comply with all the provisions of the code for new construction

in all aspects. Most of these same buildings are most likely above the

level established by the code as unsafe or dangerous. These are

primarily the buildings which the new code provisions will affect,

although they are not limited to that. Any unsafe conditions which

might occur in existing buildings must be corrected just as the code

today requires. On the other hand, if a building exceeds the code

requirements for new construction, these provisions could allow the

reduction of that level of compliance to that which is required for new

construction. For example, if a sprinkler system is in an existing

building and it is neither required by the code for new construction nor

was it a condition of prior approval of the building, these provisions

would allow the elimination of that sprinkler system. This could also

apply to any other aspect of the building which is over and above the

requirements for new construction.

But again, the majority of buildings fall somewhere below the level

for new construction and as long as there are no unsafe or dangerous

45
conditions the building may remain at its present level of compliance

or may be improved, regardless of the dollar amount of work that is

being done.

The provisions of the code which I would like to be specific on are

contained in section 2203.0 of the draft provisions. What is outlined

here are the different conditions under which an existing building finds

itself when work is intended to be done. These situations are additions,

alterations, repairs or changes of use, and the conditions which are

either over and above the code for new construction, below the level of

the code for new construction, or below the unsafe or dangerous level.

Section 2203.1 basically states what I previously described, those

facets which are over and above the code for new construction may be

reduced to the level of the code for new construction. When a building

Is less than the code requirements for new construction, alterations may

be made without further compliance to the code. Again, this Is where

the arbitrary triggering mechanism of the 25-50% rule Is eliminated.

Recognizing the elimination of the old triggering mechanisms and the

expansion of the decision-making ability of the building official, you

can appreciate the problems that this poses for him. What goes along with

the concept we are fostering Is promotion of the use of judgmental decisions

and the use of compliance alternatives, which Is what the next section

speaks to. Where compliance with the provision of the code for new construction is not practical, and we have seen that under the old rule many

Impractlcalltles can occur, these provisions allow the building official

to accept alternative solutions—solutions which achieve the basic objective of the code without necessarily meeting all the specific and detailed

requirements of the code for new construction.

This is a very important concept although it is not a new concept.

Under the present rule as I described, when the alterations are between

25 and 50% of the value of the building, the judgmental determination by

the building official is called for today. The intent of these

provisions is to further foster and promote the idea of the use of

judgmental decisions and secure the intent of the code regardless of the

cost of work being comjpleted.

Section 2203.4 speaks to additions. The basic idea Is that if you are

going to add to a building, the addition must comply with the code for

new construction to the fullest extent possible. It should not be

unreasonable to expect that any new work which will occur; that is, work

which is going on that Is not affecting anything in place or which was

not there before, should comply to the fullest extent possible. We

expect new buildings to comply with the code, and, therefore, it is not

unreasonable to expect any new construction to comply. This would

Include structural assemblies, adding floor area to a building, electrical

systems, fire safety systems, etc.

46
It was also necessary to include a subtle statement to prevent an

addition to an existing building from bringing the existing building

further out of compliance. For example, if you are adding to an

existing building and the addition eliminates some of what was

previously an exterior wall, the elimination of that exterior wall may

put the existing building out of compliance. The original building may

have relied on the open space adjacent to that exterior wall for

compliance to the height and area requirements of the building code.

Since the basic concept is that you can do nothing to an existing

building which brings it further out of compliance with the code, this

situation would not be permitted.

Section 2203.6 outlines some of the hazardous conditions which must be

upgraded, no differently than under the present building code. Imminent

threats to life safety, such as structural defects, lack of sufficient

number or capacity of exitways are identified as hazardous conditions.

These are intended to work in conjunction with the current provisions

of the building code that give the authority to the building official

to go in and exercise elimination of unsafe conditions.

From this point on the provisions speak to two situations in existing

buildings which will always occur when there is a plan for re-use of

the building. These conditions are change in use, and alteration or

repair with no change in use.

If there is no change in use, the provisions relate back to the basic

concept. You can do anything which improves or maintains the condition

of the building and you can do nothing to reduce the present level of

compliance. As previously described, however, if there are new systems

incorporated into the building such as additions or electrical systems,

they must comply to the fullest extent possible.

At this point, it was necessary to get specific about certain occupancy

classifications. Here again, I would point out that some of what is

contained in these provisions on certain occupancies, like residential

and institutional buildings, are due to specific needs or desires of the

State of Massachusetts. In concept, they could be applicable anywhere.

For example, if you increase the number of dwelling units in a residential building without changing the use group classification of the

building, then there are certain minimums which are expected. This

situation commonly occurs in the old Victorian Arts in Boston, In this

case, these provisions call for single station smoke detectors in each

dwelling unit and exit signs and lights as required for new construction. If the occupancy load of the building is increased, the exits

may have to be upgraded as necessary to provide the minimum number and

capacity. While this may apparently conflict with what I stated was

the basic concept of these provisions, that is, no required compliance

with the code for new construction, these are aspects which are not

unreasonable and which most designers would consider doing anyway.

47
These are also items which we have identified either through past

history or continuous appeals which have been experienced in the State

of Massachusetts.

If there is a change in use group, here is where we have taken the

newest steps in trying to foster a new idea about compliance with the

code. These provisions set up identification of different use group

classifications according to the building code and establish what is

called a Hazard Index Number that is intended to represent the relative

hazard of that use group to another use group. It takes into consideration the admittedly nebulous parameters that the present building code

is founded upon, such as the occupancy load of the building and the

nature of the activities and occupancy itself. High hazard occupancies,

according to the building code, naturally have a high hazard index

number. Buildings such as assembly or nightclubs, which have a high

occupancy load, also have a higher hazard index number. The hazard

index numbers are intended to approximate the relative stringency of

current building code requirements for those occupancies.

Applying the hazard index number indicates what is expected to be

upgraded when a change of use occurs. When a building has been

operating satisfactorily for one given use group, we may expect

upgrading of certain aspects of the building when it changes to a higher

hazard use group. There are a number of conditions which again are

spoken to here.

If the building is being changed to a use that is an equal or lesser

hazard, then the original rehabilitation concept applies, that is, no

further compliance with the code is expected. Here again though, the

previous position on new construction systems and unsafe conditions

still applies. If there is a change of use in which the hazard index

number is higher, these provisions establish two conditions which are

treated differently. If the change in use is one hazard index number

higher, that is, the building is going to be a slightly more hazardous

use, the provisions for the code for new construction shall be complied

with but with certain exceptions. The stated exceptions are attempts

to identify items which cannot be upgraded to new construction requirements

without causing a significant burden or which cannot be complied with

without tearing the building down. For example, window areas and

ceiling heights may not meet the code for new construction. Also, lime

mortar was commonly used in many older buildings in Boston, and does not

comply with the code for new construction. To expect compliance on

those items is impractical and unreasonable.

When the change in use is more than one hazard index number higher; that

is, we are taking a significant jump in the hazard level of the use that

exists, these provisions require full compliance with the code for new

construction. The building code today requires full compliance when any

change of use is involved. These new provisions do not affect the

current position of building codes when the change in hazard index

number is more than one number higher, but relaxes this position when

48
the changing hazard index number is only one number higher. It was felt

that this was the best first step that could be taken at this point in

time.

Another objective of this effort was to eliminate the number and types of

appeals which have gone on because of the arbitrary 25-50% rule. It is

felt that the provisions which make exception for mandatory compliance

with the code for new construction, such as the lime mortar situation,

begin to accomplish this for the State of Massachusetts. It may not

totally eliminate all appeals, but to a great extent, I think we are

going to improve the treatment of existing buildings.

The code provisions themselves are not necessarily the key to the

problems that have gone on in the treatment of existing buildings. The

biggest challenge that faces us is the attitudes and thoughts of the

people who are charged with enforcement of the codes. This approach

requires a change in the trend of thinking and increased awareness of

compliance alternatives, and in general, being reasonable and

open-minded about making decisions on alternative solutions. Again, I

emphasize that the present code to a limited extent provides for such

decision-making by the building official, when the cost of alterations

is between 25 and 50%. To provide code provisions which expand this

concept is a much smaller problem than that of promoting the proper

implementation of the concept.

In an attempt to assist in the decision-making process, there are series

of reference standards that accompany the code provisions. These

reference standards are intended to do nothing more than provide some

helpful information to assist both the building official and the

designer in coping with this new approach.

The first reference standard could probably have served as my entire

presentation because it provides a description of the application and

objectives of these code provisions.

The second reference standard is entitled, "Acceptable Compliance

Alternatives," The use and acceptance of alternative solutions to code

compliance problems is an important part of these provisions. The

purpose of this standard is only to outline and describe the thought

process which should be used in coming up with up with alternative

solutions. The examples are not detailed and are not intended to be

the "Bible" which applies to every situation. Every existing building

has its own set of circumstances, and at this point it would be

impossible to provide examples to reflect every conceivable situation

one may come into contact with. Again, many of the examples are based

on appeal cases and generally accepted situations which have been used

in the past. It is anticipated that as more and more experience is

gained in dealing with existing buildings the examples in this reference

standard will be expanded and increased.

A9
Reference Standard 3 merely lists a number of different occupancies and

identifies the appropriate use group classification and hazard index

number. These are intended to work, in conjunction with the use group

classification according to the building code and should not in any way

supersede the authority to establish a use group classification under

Article 2 of the building code. This information may serve to assist in

identifying appropriate use group classifications when in fact it may be

questionable.

Reference Standard 4 represents an area where the National Bureau of

Standards has been helpful and which we see as necessary because it

outlines what is called Archaic Construction Systems. A significant

amount of information is provided about building construction systems

which are no longer in common use, which may no longer be mentioned by

current building codes, but which may occur in existing buildings and

may in fact be acceptable. It is necessary for both the building

official and the designer to be aware of the make-up of existing buildings in order to be able to evaluate the changes that are being made

to that building. There is information on the materials and assemblies

which were used and accepted as having a fire resistance rating, as well

as information about older structural assemblies.

Again, these reference standards are definitely not the optimum answer

to all situations, I think the scope of any project from here on in

will be an expansion and improvement of this information and the

assistance type information which is going to be necessary for building

officials and designers to properly and appropriately utilize this

concept.

In summary, we hope these provisions will eliminate some of the problems

we are currently having with the building code for existing buildings,

while yet maintaining the true objective of the code in providing for an

appropriate level of life safety, health and general welfare. We look

forward to continued use, upgrading and improvement of this type of

njaterial and hope that we are moving in the right direction in

facilitating the re-use of our existing buildings.

50
PANEL DISCUSSION

QUESTION ; John McClaughry, National Conimission on Neighborhoods

In your remarks you emphasized many times the importance of

granting discretion to the building code official in dealing

with a wide latitude of code questions. What provision is

there in the Massachusetts code for dealing with disputes between the contractor and the building code official in this

gray or discretionary area?

RESPONSE ; Kenneth Schoonover, Building Officials and Code Administrators

International, Inc. (BOCA)

That is not a new problem. Whenever the building code establishes the authority for a building official to make a decision,

as with any law, the persons affected by the decision—if they

feel it is an improper decision or improper interpretation of

the code—have the right to appeal the decision of the building

official. Currently, under the building code there is a section

called, "Modifications," which allows a building official to

make a modification. Other sections of the code give the building official the authority to interpret the code. Again, any

building code will set up a mechanism for appealing the decision

of the building official, should for example, a contractor feel

that the building official has made an improper decision, or an

incorrect decision or interpretation of the code. So that

method of follow-up is the same as is in the building code and

would be the established appeal procedure.

QUESTION ; T. H. Carter, International Conference of Building Officials {ICBO)

Are there appeal procedures or boards established within the

Massachusetts Rehabilitation Code specifically, or would it be

up to the State code or whatever the case may be—the local

code?

RESPONSE ; Kenneth Schoonover, BOCA

This may be a point of confusion. These provisions as we have

drafted for Massachusetts are incorporated as a part of the

building code and tie in directly with those established procedures of the current building code. There has been some discussion about the possibility of setting up a new or different

appeals procedure, either on a regional basis or the like, but

these provisions are going to work in concert with the already

existing appeals procedures of the building code.

51
QUESTION ; T. H. Carter, ICBO

Does the State Building Code provide for an Appeals Commission

or Board, as such?

RESPONSE ; Charles J. Dinezio, Massachusetts State Building Code Commission

Yes, it does. There are two appeals boards. You can have one

if the local municipality wishes to establish one. Or, if not,

there is a State Building Code Commission which does have an

Appeals Board. You can bypass the local and go directly to the

State Building Code Commission.

QUESTION ; Bernard A. Cummings, National Association of Housing and Redevelop

ment Officials (NAHRO)

I see two model code organizations represented here. Are all of

the model code organizations committed to this type of modification of their codes to implement rehabilitation - to remove the

obstacles to rehabilitation?

RESPONSE ; T; H. Carter, ICBO

Yes, that commitment has been made and not only in the State of

Massachusetts. We have participated with the National Conference

of States on Building Codes and Standards (NCSBCS) . Also,

the NCSBCS has submitted an unsolicited proposal to the U.S.

Department of Housing and Urban Development, which Mr. Dinezio

just told you about. Here again, the three model code groups,

or the Council of American Building Officials, are part of that

effort. They all believe in this basic concept.

QUESTION ; Creighton Lederer, City of Detroit

In the example that you gave, was there any planning that went

on as to what actions would take place if in the near future,

after the reconstruction was completed, there was a fire involving loss of life, where the question of those decisions which

were made concerning stairway widths, door swings, window areas

came into question?

RESPONSE ; Paul Folkins, City of Boston Building Department

There were discussions in my office as to if a fire occurred and

there was a loss of life. We keep a record of what we do, and

a copy of the plans are always on file with us. The principles

that are used here we have used in Boston for many years when the

rehabilitation was under 50%. In fact, it would have been used

on these buildings except that it was impossible because of the

information shown in the figuresj there was no way you could ever

say they were doing work less than 50% of the physical value

of the buildings.

52
We have done this in the Back Bay area, and in buildings in

the South end. This has been a practice in Boston when Boston

had its own code up until January 1, 1975, when the State Code

came into effect. We keep the records by keeping the plans

and keeping what we have approved on file. That is the best

way we can keep records. We have had some fires in buildings

we have given permits to and in which there has been a death.

But, we try to improve our methods if that happens.

QUESTION ; Creighton Lederer, City of Detroit

My question was posed towards the difference between new construction requirements vis-a-vis the allowances that would be

made in a building like this in order to rehabilitate.

RESPONSE ; Paul Folkins, City of Boston Building Department

That really has not come up on a legal basis. Basically, we

have had buildings which do not naturally meet new standards

because they are existing buildings and have been given permits.

And, either we have given them on our own authority because

they were under 50%, or they went to the Board of Appeals.

But, no one has ever questioned, at least in Boston, the legality

of what we did and why we did it. I honestly do not know what

the answer to that question might be.

COMMENT: T. H. Carter, ICBO

We like to look at it from the other point of view. Yes, it

is, in effect, a double standard. However, a code in itself

is really a list of general requirements which really apply

to all parameters criteria. And, therefore, it has to cover

a multitude of sins. Here, we have an existing building that

has proven itself over a period of 50 years, or whatever.

And, we have specific conditions or parameters that pertain

only to that situation. And, for that reason we are justified

in many instances in not requiring new building requirements.

QUESTION ; Bennett Selekof , New York State Building Codes Bureau

We all know what the 50% value rule is, we have it. But, in

effect, what you have done in Massachusetts is to pull back

the determination to 25% and the term "replacement value" is

still a key figure. Do you have a firm definition as to what

you mean by "replacement value?" Has Massachusetts come up

with a firm definition of that?

53
RESPONSE : Kenneth Schoonover, BOCA

Under the provisions for the State of Massachusetts, the

application of the code to existing buildings is no longer

going to depend on the cost of the work being done as it

compares to the replacement value of the building. I can

tell you how the Basic Building Code defines that and it is

nothing more than the current replacement cost of the building. That being interpreted to be what it would take to

replace that building with a building of like size and use,

constructed of conventional or currently-used building

materials

.

QUESTION : Bennett Selekof , New York State Building Codes Bureau

In other words, you do not have any alteration—regardless

of the extent—even a 5% or 10% alteration that comes under

this new code?

RESPONSE : Kenneth Schoonover, BOCA

Right. The application of these provisions will not be a

function of the cost of work that is being done. That has

been eliminated.

QUESTION ; Bennett Selekof, New York State Building Codes Bureau

In the example that you gave of the warehouse where you are

reducing the hazard from a type three to a type two, the new

code would essentially have required very little except for

compliance with several items which you have here. Suppose,

for example, in this building that the existing stairway was

not 36 inches, but was 30 inches or 28 inches, supposing the

enclosure was not two hours, but say 3/4 of an hour. The

building official still has to accept such a building now?

RESPONSE : Paul Folkins, City of Boston Building Department

The building official may accept such a building. I grant you

that it says when you go to a lesser or equal hazard that

there is no additional compliance with the code; but, the

building official still has under his jurisdiction and can use,

the section we wrote under hazardous conditions where it says

"capacity of exits," it states "any required door, aisle, passage

way, or stairway or other required means of egress, which is not

of sufficient width to comply with Section 606 —that is the

capacity of it—or is not so arranged as to provide safe and

adequate means of egress." If the building official felt that

this was not safe and adequate means of egress, he does have

the authority to refuse it. It is purely a discretionary

matter.

54
QUESTION ; H. Brian Dickens, National Research Council of Canada

We, in Canada, are very much interested in the problem of

rehabilitation ourselves, and I much appreciate the pioneering that is being done in the description of what is going

on today. I would like to ask, I do not understand the

point, I think you said that under the new code, if you have

a construction or a change in occupancy classification index

two or more higher than the original occupancy, you have to

meet the full code in all respects. Am I correct in that

interpretation?

RESPONSE ; Kenneth Schoonover, BOCA

Yes.

QUESTION ; H. Brian Dickens, National Research Council of Canada

Then my question is - our code and I presume the model codes

in the U.S. - have certain requirements that are less critical

to safety, perhaps could even be considered non-safety requirements by some. Are you suggesting that an old building that

is two hazards or more above, must meet all these requirements

with no discretion at all?

RESPONSE ; Kenneth Schoonover, BOCA

Yes, except in the scope of provisions that the current building code has that allows a building official to make certain

modifications. That notwithstanding, we did not change the

scope of the current building code or how it treats change of

use when the change of use is two or more hazard index numbers

higher. Right now, the current building code says that when a

building changes use, it must comply fully with means of egress,

fire protection, and general life and safety type items. VJhen

the change of use is two hazard index numbers higher, we have

not changed that concept.

COMMENTT. H. Carter, ICBO

The hazard classification is only a function of a true hazard

to life or limb. It is not a question of some of those items

you brought up within the code that really do not relate to

life safety. I assume the Massachusetts classifications are

true life hazards.

55
RESPONSE ; Kenneth Schoonover, BOCA

Within the parameters that we set for within the hazard

index numbers, that is correct. There is a lot of discussion about how to appropriately establish a number

one single number which reflects the true hazard that that

use poses. There are a lot of facts to take into consideration, some of which a lot of study is going on right now.

Certainly, the hazard index numbers we established were

based on a given set of parameters, not all of which may be

considered appropriate or ideal. That is where a lot of

research and effort is going to go in. It is almost

impossible to establish one number that truly reflects and

takes into consideration everything that should be when

talking about a given use group.

QUESTION ; Howard Markman, U.S. Fire Administration i

My question arose from Mr» Schoonover 's presentation but it

is not necessarily addressed to him. You spoke at one time

that you could do whatever you desired to a building as long

as the compliance with the requirements for new construction

were not reduced. This to me implies a level of safety which

is somewhat less than that which would be provided by the

requirements for new construction would be acceptable, as

long as those unsafe conditions, whatever they are, do not

exist. Later in your presentation you spoke of the need for • flexibility and the acceptance of alternative solutions, which ] to me implies that the goal is one of code equivalency and

another way of achieving code compliance.

| So my question is the bottom line of a rehabilitation code

is society saying, well, because of the need to provide housing

and because of the practicality of the economics, we will

accept a level of safety for an existing structure which is less

than we would if the building were newly constructed; and, if

that is not the case, why is not this flexibility and "performance

approach" not already provided in the present day codes for new

construction?

RESPONSE ; Paul Folkins, City of Boston Building Department

I do not think that there are any existing buildings that you

are talking about in the renovation or rehabilitation field

that will meet, even after rehabilitation, new code standards.

At least I do not know of very many in the City of Boston that

will do this, and these are major rehabilitation projects.

I will give you a minor rehabilitation project—a building on I the waterfront that is an office building was renovated floor- i by-floor over a period of many years. That building does not

j

56
meet new code standards and yet, it is the headquarters of

the National Fire Protection Association. This is a fact of

life I You are talking in theory that everything should be as

100% as safe as possible—building codes themselves do not

guarantee a safe building. If you build a building today under

new code precepts, and meet them 100%, this does not guarantee

that someone will not die in the building from fire.

Given enough time and enough money, probably the people in the

model code groups could come up with such a building, but no

one would ever build it because it would be impossibly high.

What we tried to do in writing this is to come up with a document that gives you equivalent safety or a level of safety that

people will accept. If you wish to make people 100% safe, the

most dangerous occupancy in the world as far as fire is concerned is a single-family house, and if you tried to put high

precepts on single-family houses, I do not think there would be

anyone sitting here—we would be strung up because you would

never be able to build a single-family house again.

It is a matter of degree and your question as to whether you

should have these types of options in new construction—in theory

you do have these type of options in new construction, because

if you do not wish, when you are applying for a permit for a new

building, to go on totally with the precepts of the code for new

construction, because you have a special design or a special set

of circumstances, there are the appeal routes, and appeals have

been granted for new construction. There are several buildings

in Boston of new construction that have gone through the appeal

routes because of special considerations for them. The Federal

Reserve Bank Building in Boston is one that comes to mind and

there are several others. I do not know if this answers your

question, but at least it is what I think you asked.

COMMENT : Kenneth Schoonover, BOCA

You were somewhat questioning the concepts of the code regarding, more or less, a dual standard, is that correct?

COMMENT ; Howard Markman, U.S. Fire Administration

Yes. I did not mean to suggest that the compliance with the

provisions for new construction would guarantee 100% safety,

but rather I was not sure if you were saying that in a

rehabilitated structure something less than what would be provided for new construction would be acceptable.

57
RESPONSE : Kenneth Schoonover, BOCA

Yes, and to your question as to whether society is accepting

that or specifying that that is acceptable—^yes, I think it

already has. Every model building code now establishes the

legal right of an existing building to exist. There is a

clause which says legal non-conforming buildings may continue to be occupied as long as there is not work being done.

Under the present building code laws, the building code in

itself is not retroactive, the minute a new building code or an

amended building code is adopted, you cannot go into every

existing building and say, "you shall meet this building code."

Every building has a right to exist, be it conforming or nonconforming and where the problem has been is the concept of

rehabilitation, which is - if I am going to do something to an

existing building to improve it, why can^t I do that. If I

don*^t do anything to it, it can exist anyway. So, if we are

going to improve it we are saying—let's do it—we will allow

you to do it without being arbitrarily unreasonable about full

compliance with the code for new construction.

COMMENT ; T. H. Carter, ICBO

There is another way of putting it too. For a new building we

really have a double standard. In other words, you could use

the specification type provisions that are within the model

codes; but, if you want to make a more detailed design you can

use the design concepts that are recognized nationally. So,

in effect, it is kind of a double standard and we look upon

rehabilitation in the same manner, A code itself is general

and is supposed to apply to many different conditions, which we

all know is not possible. But, here we have a building which

has existed for 50 years. That, to us is field experience, that

is data to justify its continued use and why it should be treated

differently than the way you treat a new building coming in,

not knowing the congestion in the area, the water supply, many

ramifications that enter into the design of a new building*

They are unknown factors that we assume.

COMMENT ; Howard Markman, U.S. Fire Administration

That raises a lot of interesting legal issues when you get into

double standards, and makes me question then, and it is really

a rhetorical question, can the provisions for new construction

be justified? Maybe they are too strict. And, so that NFPA is

not the only one who has its headquarters criticized, when the

Fire Administration moved into its building, which is owned by

the Federal Government, it only had one exit and the people on

the sixth floor had no exits. GSA spent one quarter of a

million dollars to try to fix it up.

58
QUESTION ; John Kinney, North Carolina Department of Cultural Resources

We usually have nothing to do with building codes. However,

about 1-1/2 or 2 years ago we became involved in a dialogue

with the North Carolina Building Code Council regarding the

affect of the building code on historic properties in North

Carolina. That led to some eventual modifications to the

building code of a minor nature, mostly involving historic

house museums and some of the non-life safety provisions like

handicapped codes, etc. The roadblocks that we continually

ran into in dealing with our own code officials regarding the

consideration of what you call compliance alternatives was the

question of the liability incurred by the building official if

he starts making discretionary judgments on items that are

matters of life safety. We never successfully avoided that

roadblock. As a consequence, many of the things which we

discussed and would like to have seen incorporated in the

building code were not incorporated and were, in effect,

deferred to some later date.

How does the Massachusetts Code or the Basic Building Code

effect this? If a fire official or building official makes

a decision to follow one of the compliance alternatives and

later on that alternative can be identified as a reason for

loss of life in a fire or other hazard, what is the position

of the building official, is he legally liable for that

decision?

RESPONSE ; Kenneth Schoonover, BOCA

That is something which is probably not specifically provided

for in the code. I know within the Basic Building Code there are

clauses that speak to the relief from personal liability of

the building official and it sets out in the general administrative provisions to whatever specific extent possible, what

these liabilities are. As they relate to the specific decisions

he makes under the code, we have not really done anything new.

The code clearly states the building official shall make

interpretative decisions and judgments within the way the administrative provisions of the Basic Building Code have been

set up. They have been slightly modified by the State of

Massachusetts. But, it is a problem we are just going to have

to approach as we get experience in the decision making that

occurs under a building code. With the decisions that a building official is making right now under the building code, he is

still faced with the potential of a decision coming back and

haunting him—being a factor in a catastrophe or disaster. We

feel confident that as long as he is doing the job, as long as

he is not negligent in his duties, that will eliminate him from

personal liability.

59
When situations like that occur, they identify that perhaps

there is a problem with the code itself, and will result

usually in modifications or changes to the code itself.

COMMENT ; T. H. Carter, ICBO

I think that there is good precedent established on this.

Each of the model code groups since the middle 1950 's have

been putting out research recommendations, primarily for the

purpose of recognizing innovations, things that are not

covered in the code, new design concepts, etc., and in a lot

of cases these research recommendations are, in fact, an extension or interpretation of the model codes themselves. And,

since 1955, some 20 odd years, we have had these recommendations

challenged, we have had the authority of the building official

challenged. But, it appears that the courts will side with

the building official and his interpretative powers if he takes

the recommendation or should we say the "manual of practice,"

developed by a national association or institute, or a national

standard. This is what we plan to do, both in the Massachusetts

rehabilitation code and also with the non-solicited proposal

we have before the National Conference of States on Building

Codes and Standards.

COMMENT : Paul Moriarity, Counsel, Massachusetts State Building Code

Commission

What we need to keep in mind is that the building official is

not going to design this building, he is not going to suggest

these changes, these are something that will be proposed by the

developer on the outside, I would like to leave with the

example of a person going up to a police officer and asking

him if he may go in a rob the b^nk. Now, if the police officer

says, "Yes," that man simply cannot rob the bank—he cannot

commit a crime. The responsibility has to rest with the person

that is proposing these changes or working with the code, not

the building official.

QUESTION : Unidentified Participant

Has that been tested?

RESPONSE ; Paul Moriarity, Counsel, Massachusetts State Building Code

Commission

It has been tested in the courts, some agree with it and some

courts do not. It would depend largely on who is presenting

the case and how the case is presented. I feel satisfied with

the concept.

60
QUESTION : Irwin Fruchtman, Commissioner of Buildings,

New York City

I would just like to say in response to that, that it is not

interpretation in this case; it is discretion. There is a

difference between interpretation of a code and a discretionary

action.

That is what the building official is concerned about in a

matter like this, where the area of discretion is greatly being

expanded by this expansion of the 50% rule. I think we are

doubly concerned in bigger cities where we have a large volume

of rehabilitation work that is going on because of the manpower

problems that we all face, and the specialist problems that we

all face. We are coming into an area where people are not

trained in the plan examination, the engineers are not trained

to look at plans in this manner, where you are taking a total

look at the building and saying is it safe from this manner,

is it safe from that, and if we give a little here and give a

little there, will it still be a safe building?

Because the main way architects work is, they will come in with

a specific building and say to you, we want to decrease the

width of stairs because it will cost us "X'* amount of dollars;

or, we do not want to put this in or that in, and then they take

each minimum part you have approved as a precedent for the next

action. So, what you essentially are doing is lowering the

threshold on the codes, if you do not have the type of people

who can look at each case on a new basis. This is my concern,

although I am enthusiastic and am looking at this whole new area

because it is a matter of necessity that the city of New York

does this, because otherwise there are too many illegal conversions going on. From that standpoint, it is an appropriate

thing to do, to have guidance for city officials and other code

enforcement officials. It is just an observation but to have

guidance on the type of individual we need in building departments is something perhaps someone on the panel would like to

respond to.

RESPONSE : T. H. Carter, ICBO

This is a number one priority with each of the model code groups.

Each of us have redirected our finances, income, expenses, etc.

to take into account greatly expanded educational programs.

That is the certification of building inspectors, as well as

courses for plan reviewers to try to bring this together as far

as the educational scene. I think you will find in the future

that more and more emphasis will be placed on the education.

61
QUESTION : William Webb, Rolf Jensen and Associates

I am confused concerning what the minimum level of safety

is in an existing building below which you cannot reduce

the protection provided. In an example given, an automatic

sprinkler system could be eliminated in the rehabilitation

if that system were not originally required, or not a condition of the original permit, and were not required for new

construction. Is that correct?

RESPONSE ; Kenneth Schoonover, BOCA

Correct,

QUESTION : William Webb, Rolf Jensen and Associates

So, then the level of safety in the new building would be at

least equivalent to that of the existing code, you would be

permitting, in effect, a reduction in the level of safety

that is already provided in the building?

RESPONSE : Kenneth Schoonover, BOCA

Yes. If the conditions in a building exist over and above

what is required for new construction, it is not unreasonable

to allow those conditions which are over and above the code to

be brought down to the level that represents new construction,

since that is all we expect of new construction zmyway. That may

not be a good example. I do not think most buildings in every

aspect of their construction exceed every code requirement for

new construction, and often the sprinkler systems will be used

as an alternative to something which does not comply. It was

not a good example.

QUESTION : William Webb, Rolf Jensen and Associates

If we take the case Mr. Folkins gave that was originally a

warehouse, it probably had automatic sprinklers in it. Under

that situation, the automatic sprinklers could be eliminated

when the building was changed to apartments?

RESPONSE : Paul Folkins, City of Boston Building Department

In theory, yes. It would not be required in a new apartment

building. However, the building official in looking at it

could say, "keep the automatic sprinkler system and we will

allow you to do this," because this increases the level of

safety.

62
COMMENT

;

Kenneth Schoonover, BOCA

In that example, I think you would be allowed to do that

because that building exceeded the height and area requirements. That could be seen as an item to keep it at the level

of compliance it already is at. A better example might have

been if there were four exitways in a building where only two

are required. You could certainly eliminate one of them.

COMMENT : Murvan M. Maxwell, City of New Orleans

The area that I come from has the largest concentration of

historic buildings in the United States—an area which is

worked in, lived in, played in, day/night, everything else.

Before our building code appeals board we get cases like

Mr. Folkins' case—6 or 7 a meeting—none of this is new to

us. It is a question of biting the bullet. We certainly are

not going to put these places out of commerce. It is essential

that they stay in commerce. So, it is a matter of a meeting

of the minds on what does it take to make one of these structures

reasonably safe and usable from an occupancy standpoint; no more

than that.

Anyone who has been around a long time in this field does not

have too much of a problem in working these things out. It is

a matter of judgment and we use it everyday and we do not

worry what the lawyers will say or what the courts will say,

because what is going to happen will happen. How are you going

to cover yourself for every eventuality that will come about?

I do not know and I do not think anyone else knows. You have to

have fortitude and sit down and do the job as you see the job has

to be done. The problem is not so much with structures, like

Mr. Folkins' pointed out, we get them 6 or 8 a meeting. It is

in the slum areas and the outlying areas where property has

really gone down and become really delapidated.

Talking about whether or not you are going to convert a warehouse into an apartment unit, so what I We do it everyday and

have been doing it for years. It is the fringe areas that pose

the problem and how much you are going to give in those fringe

areas.

It is a matter of judgment and can be worked out without a lot

of problems. We have an adapted version of the West Coast code

and we have no serious problems. We do not worry about what the

lawyers are going to think and what the courts are going to

think—we just do the job.

63

Session on Technical Evaluation Guidelines and Their Development

Moderator: James H. Pielert, Group Leader

Building Rehabilitation Technology

PANEL

Bernard A. Cummings

National Association of

Housing and Redevelopment Officials

Harold E. Nelson

Chief, Program for

Design Concepts

Center for Fire Research

NBS

Walter E. Lewis

Professor

Department of Architecture

University of Illinois

65
5ift

liiC

1!iiis

fita«Sf
SESSION MODERATOR

James H. Pielert

Group Leader, Building Rehabilitation Technology

Center for Building Technology, NBS

Mr. Pielert received a B.S. in Civil Engineering from the University of Maryland

in 1961, and a M.S. in Civil Engineering

from Lehigh University in 1965.

Mr. Pielert joined the staff of the Center for Building Technology in 1971. He

has served in management positions in various CBT program areas, including the HUD

Operation BREAKTHROUGH Program and mobile

home research and standards development.

Currently, he is the Group Leader, Building

Rehabilitation Technology.

Prior to joining NBS, he was employed by

Bethlehem Steel Corporation and was responsible for research in the area of

structural steel building products; and by

H. H. Robertson Company, where he researched

the application of light gage steel, aluminum

and plastic products to the building industry.

Mr. Pielert is a member of the American

Society of Civil Engineers and is a registered

Professional Engineer in Pennsylvania and

Maryland.

The session this morning pointed out very clearly the need for technical

guidelines which would be needed to successfully implement the type of

performance rehabilitation code that was discussed. Ken Schoonover

talked about judgmental decisions which are going to have to be made by

building officials, design professionals and others involved in making

these decisions. And, this is really the scope of this session on

Technical Evaluation Guidelines and Their Development.

To give you some background on the work that has been carried out in

this area at NBS, this year we are completing several studies which

address the issue of technical needs in regard to rehabilitation, NBS

awarded a contract to the National Conference of States on Building

Codes and Standards to study the needs of the model code organizations

and selected State and city regulatory agencies relative to building

rehabilitation. Additionally, a grant was given to the Massachusetts

Institute of Technology to develop the report, "An Investigation of the

67
Regulatory Barriers to the Re-Use of Existing Buildings," This report

was handed out In your package. This study examined the regulatory process In Massachusetts for existing buildings to Identify the types of

problems which are being encountered.

Generally, the results of these studies Indicated that a technical basis

for rehabilitation decision-making Is needed. As an example, codes may

not address the type of construction represented In many old buildings.

Technical data are no longer available for many older systems making It

difficult to evaluate Its performance relative to existing codes and

standards. Secondly, evaluation methods needed to determine the condition of existing buildings may not be adequate. These Include test

methods for laboratory and In-sltu evaluation, analytical procedures,

and field Inspection guidelines. And third, and this has been touched

on several times this morning, the technical bases of regulations need

to be developed. The technical rationale for code provisions relative

to celling height, ventilation requirements, floor areas and other

things discussed this morning needs to be studied. It could be that

these are excessive and cause Increased rehabilitation costs.

I would like to take a minute to discuss some activities going on In

these areas at the Center for Building Technology. We are In the

process of developing outlines of technical manuals for selected areas

to aid In the decision-making process for rehabilitation. Figure 1 lists the types of Information which will be Included In these manuals.

The first area Is test methods. Test methods are needed to evaluate the

existing condition of a building. This Includes both destructive and

nondestructive testing. Methods of analysis need to be documented, and

If necessary developed, to assist In the evaluation process. In many

cases It may be possible to analytically evaluate the conditions of

various building systems. As an example, the condition of the plumbing

system and Its capability to accept additional loads may be of concern

In a rehabilitation project. If this can be determined by calculation,

It may be possible to keep down costs associated with expensive field

testing or the eventual replacement of a suspect plumbing system. Field

Inspection methods are very Important for determining the condition of

the building In order to compare It to some code document or another

technical base.

The next Item is data on performance of existing construction. We know

existing buildings contain construction systems which are no longer in

use and for which the design data is not generally available. These

manuals would include data or the sources of the data for these systems

in order for those involved in rehabilitation to make the technical

decisions. And finally, data on other building rehabilitation experiences represent a base which can be used by others to simplify the

decision-making process.

Figure 2 illustrates a series of technical manuals containing

state-of-the-art listings of technical data for building components and

specific health, safety and general welfare attributes. The attributes

68
include strength and stability, health and sanitation, accident safety,

fire safety, energy conservation, and security. Others which may be

included are acoustics and access for the handicapped. A manual is

needed for each attribute and would include, where available, data on

structure; enclosure and division of space; mechanical systems; plumbing

systems; and electrical distribution systems. This format would provide

a basis for application of alternative solutions within attributes. For

example, within the health and sanitation attribute an alternative solution for natural ventilation would be the addition of mechanical ventilation. There also will be potential interrelationships between the

various attributes. The fire safety and security attributes may have

conflicting technical aspects in regard to rapid egress versus locks.

Work is now being completed on the development of outlines of the

strength and stability, health and sanitation, and accident safety

manuals. The development of the strength and stability manual will take

place in FY79. Work on the other technical manuals will depend on the

availability of additional funding.

An important area where work is needed is fire safety. Studies have

shown fire concerns are significant in building rehabilitation. We are

fortunate today to have a speaker from the NBS Center for Fire Research

to talk on a fire evaluation system for existing buildings.

69
Figure 1: Types of Information to be Included in Manuals

TECHNICAL MANUALS

• Test methods for nondestructive evaluation

of existing construction

• Test methods for destructive evaluation of

existing construction

• Methods of analysis to predict the performance

expected of existing constructions • Field inspection and evaluation methods

• Data on performance of systems no longer in use

• Data on rehabilitation experiences

Figure 2: Series of Technical Manuals

MANUALS FOR EVALUATION

ATTRIBUTES

COMPONENTS ######### ^

STRUCTURE

ENCLOSURE AND

SPACE

MECHANICAL (HVAC,

ELEVATORS, ETC.)

PLUMBING

ELECTRICAL DISTRIBUTION,

LIGHTING. COMMUNICATION

70
A "Professional Practice" Approach to the Rehabilitation Process

by

Walter E. Lewis

Professor, Department of Architecture

University of Illinois

Professor Lewis is an Architect and

Professor of Architecture in the Department of Architecture at the University

of Illinois

.

Ten years ago. Professor Lewis pioneered

an innovative Academy for Code Administration and Enforcement at the University

,

which has offered award-winning education

and training programs for practicing code

administrators and enforcement officials

.

Last year. Professor Lewis created a unique

graduate studio within the professional

masters-degree program in the Department of

Architecture called the Professional Practice Studio. The first project undertaken

involved studies of adaptive re-use of

buildings in the declining downtown district of a midwestern city of about 60,000

population.

He serves on the Board of Trustees and

Executive Committee of the National Academy

of Code Administration, which is developing a national voluntary , competency-based

education/training and professional certification program for code administrators.

The Department of Architecture at the University of Illinois at Urbana/

Champaign has embarked on a new and ambitious program in graduate education

linked with continuing professional education for practitioners. This

new program is called the "Professional Practice Studio." One of the first

projects undertaken in the Studio explored incentives, through the building

rehabilitation process, to restore vitality in a declining "downtown" of

a midwestern city.

The work was performed in the newly-organized Professional Practice Studio

by twelve graduate students in their terminal year of the six-year professional curriculum in Architecture at the University of Illinois. To

assist the two graduate professors who coordinated the work in the Studio,

71
a Professional Practice Resource Group of five or six practitioners were

sought to monitor and periodically critique the Studio work. A list was

developed of 17 architects with distinguished records of architectural

practice, many of whom had also completed successful projects in one or

more of the complex facets of the building rehabilitation process. The

entire list was invited to serve on the "Practice Group" in hopes that

at least five or six practitioners would accept this crucial leadership

role. Surprisingly, since no departmental funds could be budgeted for

travel, lodging or other expenses of the Professional Practice Resource

Group, all 17 endorsed the idea, pledged their personal time and money and

as a result, the Professional Practice Studio became a reality I

Thus, an educational format was created with expert professional input to

deal with complex urban and architectural issues in a manner that helps

bridge the transition from academia to professional practice. The Studio

helps the Department of Architecture meet three important goals:

1. Education at the "cutting edges" of architectural practice;

2. Research in a professional discipline with expert professional

advice and counsel to create new knowledge; and,

3. a vehicle for Public Service to the profession, local regional

community, the State and perhaps even the nation.

New learning potentials were immediately recognized by all who participated —graduate students, teaching faculty, practitioners and our Studio "clients

alike. Projects undertaken in the Studio are complex enough to accommodate

either individual or group studies by the case study or project method.

Participants learn "by-doing" on relevant research projects having "real"

clients, "real" budgets, "real" sites, and the "real" complexities of urban

development and redevelopment.

Practitioners became valuable resources in courses other than the Studio,

especially the first professional course for freshman, "Introduction to

Architecture and Environmental Design ." During the periodic Practice

Group visits, continuing education "interact seminars" were organized to

address current issues of interest to practitioners, such as Marketing

Architectural Services, Professional Ethics, Tax Increment Financing and

so on.

Experience to date with the Professional Practice Studio and the Professional Practice Resource Group have led us to study the possibility of

establishing an entire Professional Practice Option running parallel with

other graduate options currently offered in the six-year program; Design,

Structures, Historic Preservation, and Housing and Management (which is

coupled with a Master of Business Administration degree)

.

One of the first projects undertaken in the Professional Practice Studio

was a Rehabilitation Feasibility Study. It was a public-private joint

venture to determine the physical, market, and economic feasibility of

creating a comprehensive cultural arts complex in the heart of the

72
"downtown" district of Champaign, Illinois. In addition to our "client,"

the National Academy of Arts—a not-for-profit private corporation—other

parties to the joint venture included the City Council and the Downtown

Development Council. All other parties interested in the potential for

downtown revitalization were invited to review sessions. The proposed

project tested the feasibility of creating, in phases, a $10-$15 million

cultural arts complex in the "downtown" district to house the international

high school program and the professional company of the National Ballet of

Illinois, both divisions of the National Academy of Arts, and to serve the

educational and cultural arts needs of the immediate regional community.

When completed, the Performing Arts Center would consist of new construction of certain facilities on existing parking lots, coupled with the

rehabilitation of an existing six-story hotel no longer used for this

purpose, and an adjacent three-story office building, all to meet program

requirements of the "client"—the National Academy of Arts. The elements

in the Academy Architectural program included in the feasibility study were

New Construction - (on "open" land used for municipal parking adjacent

to the hotel)

• Performing Arts Theater (1800 seats); including Practice Rooms;

Recital Halls; Set/Costume Shops; and

• Parking Facility for 500 cars.

Rehabilitation of Existing Buildings (a six-story hotel and threestory office building)

• Administration and faculty offices for the National Academy of

Arts, a change in use from the existing residential occupancy;

• Classroom facilities for an accredited junior/senior high school, a

change in use from the existing residential occupancy;

• Training facilities for a regional community cultural arts program

in dance, music, and theater arts, a change in use from the existing residential occupancy; and

• Housing and boarding facilities for 200 Academy students attending

the international high school and the professional company of the

National Ballet of Illinois, a permitted use under the existing

residential occupancy.

The Studio project offered an excellent educational context for studying

the complexities of urban redevelopment and rehabilitation and, depending

on the final results of the feasibility study and future courses of action,

such a project would offer:

• Positive stimulus to needed downtown development;

• Continuous year-around cultural programs that would provide regional

attractions to bring thousands of citizens directly into city center

creating new commercial market demand;

73
• Adaptive re-use of two existing downtown buildings in conjunction

with the construction of major new structures;

• Rehabilitation of the existing hotel to provide resident housing

for 200 Academy students creating 24-hour residents in the downtown district;

• Theater performance that would generate new evening parking demand

in addition to normal daytime commercial parking demand helping to

optimize parking structure financing;

• Comprehensive traffic, parking and other studies, in cooperation

with city staff and regional plan commission to create a new information base to assist public and private decision-making; and,

• A test of Tax Increment Financing—a new Illinois law to assist

local governments in redevelopment districts.

Graduate students in the Professional Practice Studio were divided into

three teams to study the problem at three "scales." One team, using the

entire downtown as the study area, developed major new studies to add to

the information base. Another team studied the design potential of the

new construction required to meet program requirements for the Performing

Arts Theater and Parking Structure. The third team studied the redevelopment and rehabilitation potential of the two existing buildings on the site

to meet the "client's" remaining program requirements.

One definite conclusion can be drawn from the Studio work: if major

stimulus for urban redevelopment and rehabilitation is to be successful,

a much broader, up-to-date information base is necessary for decisive

public and private decision-making.

Redevelopment feasibility requires measurement and evaluation of two

dependent variables: (1) the community's readiness to act, and (2) the

community's willingness to act . The first depends on accurate, current

information documenting the city's redevelopment capacity. Such an information base is essential to evaluate redevelopment demand required under

project plans for urban revitalization. Thus, a project is feasible, under

the readiness test when the community's redevelopment capacities—in terms

of public facilities and services to accommodate requirements for new

traffic flows, new parking demand, new utility services, new police and

fire protection, to name just a few of the capacity factors—meet or

exceed the demand factors for such facilities and services required under

the redevelopment plan.

Research to document the city's capacities, as well as the demands the

"client's" plan would place on these capacities, were well within the

scope and capabilities of the participants in the Professional Practice

Studio. From the beginning, however, the Project feasibility under the

"willingness" test was beyond our ability to measure. There exists in

Champaign no clear public /private community consensus on redevelopment

goals or objectives; the city's Comprehensive Plan has not been updated in

26 years; and, while there have been numerous attempts to "Save Downtown,"

progress toward this goal moves at a glacial pace.

74
The first project undertaken in the Professional Practice Studio, even if

nothing comes of it, offers a stimulus to heighten community awareness.

It has been an excellent learning experience in the rehabilitation process

for all who participated in the Professional Practice Studio. Some of

the details of this project are summarized.

A graphic "Definition of the Building Process" was prepared in terms of

Need, Program, Design, Construction and Use to help individual team members

identify which phase in the Process was involved. Figures 1 through 5

illustrate these five phases. Figure 6 illustrates the management of the

development process.

Base maps were drawn to document existing conditions in the downtown study

area. These data describe Regional Access; Zoning and Uses of buildings

in downtown; the Built Area versus open space; a mapping of Building Value;

Land Value; Transportation; and. Ownership of land and buildings. Additional

maps were draw describing the style, character and materials used in buildings

as well as many alternate studies for redevelopment in the downtown area.

Figures 7 and 8 are examples of a Use/Zoning base map, and a Building Value

base map, respectively.

The student team who examined the rehabilitation of existing buildings

developed a process for documenting existing and revised conditions. Essentially, this process consisted of four steps:

1. securing original drawings and specifications, if possible;

2. preparing 8-1/2" x 11" field survey documents which included small

scale plans, elevations and cross-sections, and schedules to permit

field information to be recorded efficiently;

3. preparing drawings to document the existing and revised conditions;

and,

4. detailing the revisions to be used in the rehabilitation.

Examples of the field notes taken on the small scale drawings and schedules

show the conditions to remain and those to be altered. Code violations were

starred in "red" to call attention to the re-design work that had to be

done' to correct the violations.

Figure 9 is an example of a small scale drawing portraying the conditions

of the fourth floor of the existing six-story hotel, while Figure 10 is an

example of the form used to portray the existing conditions and what needed

to be done to rehabilitate this structure for its intended use.

Figure 11 is an example of a scale drawing noting existing /revised conditions. Finally, Figure 12 is an enlarged city street map illustrating the

study area.

The Professional Practice Studio has received much positive media coverage.

The Morning Courier of April 10, 1978, stated that the on-going program in

the city of Champaign is "a project that participants view as something

more than an academic exercise .

75
Figure 1; Phase 1. Need

I DEFINITION OF THE BUILDING PROCESS! 0

r NEED

CONTROL

CONDITIONS

• Zoning • Codes • Standards • Health and

safely • Environmental • Socio-political •

FEEDBACK • Mhy • What

/ 1 J •Wi>«»

V >^ •Who

\. ^ • Mow

1

DEFINE

FACILITY/SITE

NEED

ESTABLISH

FACILITY/SITE

NEED

VERIFY

FACILITY/SITE

NEED

REQUIREMENT^ / CAPaBI LITI Eg"

NATURAL

CONDITIONS

MAN-MADE

CONDITIONS

DEMAND

CONDITIONS

ECONOMIC

CONDITIONS

Geo-physical

Biotic

Community

facilities Community

service Space

• User • Owner • Product • Function • Time • Manpower •

• Capital cost • Investment • Profit • RisK • Efficiency • Motivation •

DECISION

" POINT

NEED

VERIFIED MaDECISION TOPROGRAM

Figure 2 ; Phase 2 . Program

ESTABLISH

FACILITY/SITE

CRITERIA

EVALUATE

PROGRAM

ALTERNATIVES

SELECT

FACILITY/SITE

PROGRAM

I DEFINITION OF THE BUILDING PROCESS 1 Q

OPTION/

ACQUIRE

LAND

RgQUmgMdNTS / Capabilities

CONTROL

CONDITIONS

NATURAL

CONDITIONS

MAN-MADE

CONDITIONS

DEMAND

CONDITIONS

ECONOMIC

CONDITIONS

• Zoning • Codes • Standards • Environmental • Energy • Quality assurance • Socio/

political

Climate Environmental

Geo-Physical

Biotic

Site systems

Building

systems

Equipment

Materials

• User needs

functional behavioral occupants • Time • Marketability • Manpower • Quality Assurance •

• Capital Cost • Investment

cost • Financing

cost • Maintaining

cost • Operation

cost

FEEDBACK • Why • WHiil

( \J • wneio V _ • Who ^ • Mow

.... DECISION " POINTPROGRAM

VERIFIED 3^DECISION TO

DESIGN

76
Figure 3: Phase 3. Design

I DEFINITION OF THE BUILDING PROCESS] 0

I DESIGN

J

ESTABLISH

DESIGN

PROCEDURE

ACQUIREy

OPTION

LAND

EXECUTE

PRELIMINARY

DESIGN

VERIFY EXECUTE

DESIGN FINAL DESIGN

REQUIREMENTS / CAPABILITlgT

CONTROL

CONDITIONS

NATURAL

CONDITIONS

MAN-MADE

CONDITIONS

DEMAND

CONDITIONS

ECONOMIC

CONDITIONS

FEEDBACK • WAy •Whit f , 1 •When

I V J V •Who

•How DECISION

•* POINT

DESIGN

VERIFIED

• Zoning • Environmental • Structural • Materials • Cost • Codes analysis • Architectural • Resources estimate • Standards • Site analysis • Electro/ • Land • Insurance • Environmental mechanical available • Financing • Health and • Acoustical • Real estate Safety • Interior system acquisition • Energy • Equipment • Feasibility • • • Evaluation • • • • • •

• • • • • •

DECISION TO

CONSTRUCT

Figure 4: Phase 4, Construction

DEFINITION OF THE BUILDING PROCESS ] Q

VERIFY DESIGN

CONSTRUCT

ABILITY

ESTABLISH

COST

DEVELOP

PROCEDURE

EXECUTE

CONSTRUCTION

CONTROL

CONDITIONS

FEEOBACK • Why •Wh«l A.J • Wh«n

I \J • Where V M • Who ^ aHow

RgQUIftEMENTS / 6AI^ABlLlTlg^

NATURAL

CONDITIONS

MAN-MADE

CONDITIONS

DEMAND

CONDITIONS

ECONOMIC

CONDITIONS

• Codes • Climatic • Site systems • Standards • Geo-physical • Building system • Health and • Geographical • Community

safety location facilities • Ordinances • Utility • Labor services

jurisdiction • Construction • Environmental Equipment • • Transportation •

services •

• Warehouse/

Distribution

• Materials/ products

availability • Manpower

availability • Construction equipment

availability • Time •

• Cost

estimates • Construction

financing • Bonding • Insurance • Time • Competition •

••

*. DECISION

POINT

CONSTRUCT

VERIFIED

DECISION TO

USE
Figure 5

:

Phase 5, Use

1

ESTABLISH

USE

FURNISH/

EQUIP

FACILITY

ESTABLISH

0/M

PROCEDURES

I DEFINITION OF THE BUILDING PROCESS! (3

d USE OCCUPY

SPACE

OPERATE/

MAINTAIN

SPACE

EVALUATE/

MODIFY

DESIGN

CONTROL

CONDITIONS

Health and

safety

Energy

utilization Ordinances

FEEDBACK • Why

• Wner> • wnert • wno • How

REQUIREMENTS / CAPABILITTFs"

NATURAL

CONDITIONS

MAN-MADE

CONDITIONS

DEMAND

CONDITIONS

• Environmental

impact • Buildingsystems • Site systems • Occupant

furnishings/

equipment • Community

services

Owner

User

Leaser/

rent

DECISION

POINT

USE

VERIFIED

|_^^

ECONOMIC

CONDITIONS

• Taxes • Depreciation • Financing • Operation

costs • Maintenance

costs • Insurance

costs

DECISION

Figure 6; Management of the Development Process

CREATING BETTER COMMUNITY ENVIRONMENTS

MAXIMUM

JUOGMENT

COMIVIUNITV COALS

COIVIPPIEHCIMSIVe PLAN

OeVELOPIVIIENT COAU

DEVELOPMENT PLAN MAXIMUM

RISK

APPROVAL BY JOINT VEIMTURES

z

.n9

ii<

1°Z (3

r

4>

PUBLIC

NATURAL

CAPACITY

MAIM-MAOE

CAPACITY

MARKET

CAPACITY

ECONOMIC

CAPACITY

DOMAIN

PRIVATE

NATURAL

CONDITIONS

MAN-MAOE

CONOITIONS

MARKET

CONDITIONS

ECONOMIC

CONDITIONS

DOMAIN

APPROVAL BY RIGHT

I

^ u °l

IH

2<

02

Zt in

2

MINIMUM POLICB PDWan LAW* PnOPBRTV RIQMTS MINIMUM

JUDGMENT onoiNANCBS ANo cooes PdOPITABILITV RISK

MANAGING THE DEVELOPMENT PROCESS

-7 O
Figure 7; Use/Zoning Base Map

Spmg 1978 Graduate ArctTtedual Desigi Stuio Deparlmeni d A^chrtedue Unversity d Inos at Urtjana-Champagp
Figure 8: Building Value Base Map

II, to.: 1.

" CL W /r-ion n nl'i'loDnDanl

Downtown Champaign: 78 Plus

Building Value i! r'

•Jt'.UiliB I9-(4M

HH^Hmotv t>««i taw Unt) ri/8 Gf..H)te Afcm-ciLril [>>spi Stirto Dtxnnrrnl d /vchrttfine L»ivasrty d fcXK at UrtMfB - Oryrpaq

8n
Figure 9: Small Scale Drawing of Fourth Floor

'^OCPARTMBNT OP ARCMlTBCTURE

PR^ESSIOMAL PRACTICE STUDIO

UNIVER&ITY OP IU.INOIS • UlUC

- — J

SURVEY OF EXISTING COKDlTiOUS

PROJECT P»!tf»«r JDATK:

theae three rooas In fairly good cooditlon

•ddlclonal outlet* req

•ergency light

landing width les Chan atair width

aBoke & heat detector cove^

Biasing

fuse box

reaove wood

fiber board

entire corridor

door reduces

ezltway

replace loose tile

extend new carpet

to exit

replace broken

*lre glass in •xlt door

debris in hall

poor housekeeping/

remove comb, debris

replace & enclose wire

harness

fuse box

door reduces

exit width

low beaverboard

celling throughout

replace loose tile/extend new

carpet to door

"ove radiator

decreasing door

exit width

fire stops req. at floor & ceiling

'step down

'fire escape'

iji code violations • general observations — ^ • •FOURTH FLOOR Honru PMWN - JMM sheet'

NATI(9NAL ACADEMY 4 ARTS • 73 PLUS

C»«Ct<C6:

R-l
Figure 10: Form Used to Portray Existing Conditions and Rehabilitation Needed

floor

4

project nam* : NATIONAL ACADEMY OF ARTS

78-PLUS

contractor : general pro) no: 78-i data: 3-1-78 shno: 3 SCHEDULE OF EXISTING CONDITIONS

ROOM floor baaea walla calling doora windowa LEGEND

APPLICABLE

NO NAME

P

NOT APPLICABLE

M T repair k ref Inlah

s' g g

Q

SS

X T remove & replace w

U)H

25 < M

<

* T alter: aa per plan

0

N

N

M M

lu 0

N

N ASTER/I

0

a

av. 83

4

atet : leave aa la

Ehu

E

a

a:u

CO

I-: 81

* coda violation

(J Me- u U

8

3

U M 3

0. J w see

aei REMARKS

432 MUSIC PRACTICE RM 2 I 2 2

433 MUSIC PRACTICE RM 1 2 2

• 14 TOILET 2 2

435 MUSIC PRACTICE RM 2 1 2 2

436 TOILET 1 1 T 2 2

437 MUSIC" PRACTICE RM 2 1 2 2 438 MUSIC PRACTICE RM 2

1

1 2

2

2

2

439 TOIIET 1 2

440 TOILET 1 1 2

441 MUSIC PRACTICE RM 2

2

1 1

1

2

2

2

*2

2

2

2

442 MUSIC PRACTICE RM

443 TOILET 1 1

444 TOILET 1 1

445 MUSIC PRATICE RM 1

1 1 1 ^2

*2

446 MUSIC PRACTICE RM 2 1 t= 2

447 STAIRS 2 1 *J

1978 - Professional Practice Studio

82
Figure 11: Scale Drawing Noting Existing /Revised Conditions

tS£>Aove wiKjoow eucuosc

RerAove f*iite e^stCApe ami*

83
Figure 12 : Street Map Illustrating Study Area

84
A Fire Evaluation System for Health Care Facilities

by

Harold E. Nelson

Chief, Program for Fire Design Concepts

Center for Fire Research

National Bureau of Standards

Mr. Nelson received a B.S. in Fire Protection and Safety Engineering from the

Illinois Institute of Technology in 1950,

Since joining the staff of the National

Bureau of Standards, Mr. Nelson has worked

in several safety and fire related programs.

Prior to joining NBS, he served as the

Director, Accident and Fire Prevention Division of the General Services Administration,

providing advice on safety and fire considerations of GSA, including design, construction,

operation and repair of Federal buildings.

Currently, Mr. Nelson is Chief of the

Program for Design Concepts in the Center

for Fire Research, where he heads an interdisciplinary effort to synthesize and

integrate research and technology into

rational and applicable technology and concepts usable in design, regulation,

inspection and maintenance.

Mr. Nelson is a member of several professional societies and serves on a number of

national committees. He is the author of

numerous technical papers in safety and

fire-related areas.

The ideal goal of life/fire safety design is to prevent all fire deaths,

injuries and losses under all imaginable circumstances. Practically,

however, society can neither forestall all loss of life nor spend limitlessly to avert loss of life due to fire. Building codes are designed

to provide a minimum acceptable level of life safety at a cost society

is able and willing to support. The Life Safety Code of the National

Fire Protection Association (NFPA No. 101) is a voluntary code widely

accepted for setting acceptable fire safety levels. The code provides

fixed solutions for life safety in designated occupancies, but allows

"equivalent" solutions. However, it does not define alternative

solutions nor provide a mechanism for evaluating equivalence.

The Center for Fire Research, with support from the Department of

Health, Education and Welfare, has developed a system for determining

how combinations of widely-accepted fire safety systems and arrangements

may provide a level of safety equivalent to that required in the 1973

85
Life Safety Code. The system provides flexibility to the designer of

new facilities and to the renovator of existing health care facilities.

The major concepts forming the basis for code-equivalence are:

a. Occupancy Risk - the number of people affected by a given fire, the

level of fire they are likely to encounter, and their ability to

protect themselves.

b. Building Safety Features - the ability of the building and its fire

protection systems to provide measures of safety commensurate with

the occupancy risk.

c. Safety Redundancy - in-depth (redundancy) protection, through the

simultaneous provision of alternative safety methodologies such as

containment, extinguishment, and people movement methodologies.

Each methodology provides at least its own independent minimum code

level of protection. The design of the complete fire safety system

is intended to ensure that the failure of a single protection device

or method will not result in a major failure of the entire system.

An adequate life safety system must include a building safety system

commensurate with the occupancy risk. The Fire Safety Evaluation System

provides a model for evaluating the fire risk in a building, by

incorporating factors such as mobility of people, number of people at

risk, height of building, etc. The calculated risk level provides a

minimum target for which levels of protection must be provided by the

nature of the building design supplemented by appropriate passive and

active fire protection devices.

The evaluation system is also a technique for obtaining a quantitative

measure of the level of safety provided by a protected building. This

level is determined from an evaluation of the various construction

elements and fire protection features. The system measures both the

gross level of safety and a set of safety subsystems related to

containment, extinguishment and people movement. These subsystems are

individually graded to evaluate the depth of redundancy in the building

fire safety system. The evaluation system is a mechanism by which the

designer can combine a wide variety of fire safety elements into a

health care facility plan that provides the level of fire safety

required to balance the calculated risk levels.

This evaluation system applies to institutional buildings used for

health care purposes, involving sleeping facilities for the occupants.

In its present form, it was not designed for outpatient clinics or other

facilities where all of the occupants are normally awake.

The system to be described covers all of the aspects of building fire

safety currently covered by the Life Safety Code. A few of the items

related to built-in utility systems and to operational features and

furnishings (fire evacuation plans, fire drills, draperies, etc.) have

86
been excluded from the grading systems. However, these are covered as

mandated items in an attachment to the evaluation form. To be considered

as having demonstrated equivalent fire safety, it is necessary that the

facility satisfy these requirements in addition to the basic fire safety

evaluation.

The purpose of the evaluation system is to provide a technically-based

mechanism applicable to health care facilities for:

a. Evaluation of an existing health care facility to determine how the

actual level of fire safety in that facility compares to the level

of fire safety that would be provided by explicit conformance to

the requirements of the 1973 Life Safety Code.

b. Evaluation of various alternative approaches available to upgrade an

existing facility to a level of fire safety that meets or exceeds

the level prescribed by the Life Safety Code.

c. Evaluation of a proposed new facility design to determine how its

level of fire safety would compare to that required for such a

facility by the Life Safety Code. In this aspect, the system can

also be used as a design instrument to determine various

alternatives that can be considered.

d. Evaluation of the cost effectiveness of alternate fire safety

designs and methodologies.

e. Quantitative evaluations of the relative degree of protection

involved in a facility or a design feature, as compared with that

required by the Life Safety Code.

The evaluation system provides a method for determining the design

features needed to provide equivalence to the 1973 Life Safety Code.

Equivalency, for the purpose of the system, is judged by comparing the

total fire safety level prescribed by the Life Safety Code for health

care facilities to the actual safety level of a particular design or

an actual facility.

The Life Safety Code represents a consensus view by knowledgeable

professionals of the minimum standard for fire safety necessary to

safeguard the public interest.

Equivalency determination is based on the concept that, while the Life

Safety Code does not include a specific statement of the level of safety

provided, it is possible by examination of the Code requirements to

establish a baseline for comparing the level of safety provided by

strict conformance to its requirements with the level of safety provided

by alternative systems of safeguards. This comparison can be made on

the basis of the total safety performance of the building, including all

of its safeguards; without making direct comparisons between a specific

Code requirement for an element and the corresponding element as it

87
exists in the building. The concept is suitable for use with any of

the recent editions of the NFPA Life Safety Codes for 1967, 1970, 1973

and 1976. The following reference sections are quoted from NFPA

101-1973:

"1-3118. Nothing in this Code is intended to prevent the use of

new methods or new devices, providing sufficient technical data is

submitted to the authority having jurisdiction to demonstrate that

the new method or device is equivalent in quality, strength, fire

resistance, effectiveness, durability, and safety to that prescribed

by this Code,"

"l-4113(c). The specific requirements of this Code for existing

buildings may be modified by the authority having jurisdiction to

allow alternative arrangements that will secure as nearly equivalent

safety to life from fire as practical, but in no case shall the

modification be less restrictive or afford less safety to life than

compliance with the corresponding provisions contained in this Code

for existing buildings. (See also 1-3118)."

Evaluation of equivalency of fire safety is through consideration of

three separate concepts. The first is occupancy risk, judged primarily

on: how many people are susceptible to a single fire exposure (level of

risk), what is their capability to safeguard themselves, and what is the

nature of the exposure to which they are being subjected. The second is

the capacity of the building and its fire protection systems to provide

a safe environment commensurate with the risk. The third is the degree

of redundant capabilities to ensure the preservation of safety in case

of the failure of any one safeguard or method.

Development of the fire safety evaluation system consisted of three

operations: system design, professional judgment review and critique,

and system testing.

a. System Design. This consisted of: (1) analysis of the stated

requirements of the 1973 Life Safety Code versus the fire safety

function(s) of each requirement; (2) organization of the results of

this analysis into a format suitable for obtaining professional

judgments of the comparative worth of the fundamental code requirements relative to the Life Safety Code objectives for health care

facilities; (3) development of a computer program to evaluate

alternative designs and fire protection systems; and, (4) iterative

incorporation of system changes resulting from the professional

judgment review and system tests.

b. Professional Judgment Review. The professional judgment review was

made by two different groups: (1) an NBS group, through the

mechanism of a "Delphi" exercise; and, (2) an outside review group.

The Delphi group (an ad hoc group of qualified fire protection

engineers from the Center for Fire Research, NBS) refined the

format, established initial values of the safety parameters, and

88
provided judgment values for selecting individual safety parameters

in the redundancy evaluations. The outside consulting group

consisted of prominent persons in the field of regulation and

specification of fire safety requirements in health care facilities.

The group provided broad-based technical and judgmental information,

improving both the format and the final values assigned to the

safety parameters and the redundancy factors.

c. System Testing. The testing involved a series of exercises to

determine the validity of the fire safety evaluation system. These

exercises included: field tests of actual facilities by NBS

personnel; examination of many evaluation worksheets completed by

health care facilities' owners and engineering staff, and by code

certification and inspection authorities; and, computer analysis of

alternative design systems.

The system that has evolved from this effort provides a means of mixing

recognized and proven fire safety systems and approaches and evaluating

these mixes in terms of the overall fire safety performance of a

facility. It permits comparative evaluations of the fire risks and fire

safety factors actually present in individual facilities or design.

Those features that are in excess of minimum safety requirments are

given appropriate credit, reflecting the degree of additional safety

actually provided. The credit, however, is limited in this application

to the methodological areas where the safeguards provide credible

improvements in safety. Conversely, features that increase one or more

aspects of fire risk are appropriately charged for their detrimental

impact on safety. The result is intended to be an assessment of total

safety performance as compared to a minimum code safety level, which

provides opportunity for cost reduction, wider choice of design

alternatives, and operational flexibility at greater levels than

currently available through explicit compliance with the Life Safety

Code.

The most important limitations of the evaluation system are:

a. As presently developed the evaluation system applies only to health

care facilities of the types covered under Chapter 10 of the 1973

Life Safety Code.

b. The results are expressed in equivalency to the level of safety

achieved by the Life Safety Code, and should not be construed as

a measure of total or absolute fire safety.

c. The system, like all existing methods for regulating or evaluating

fire safety, is only partially supported by technical information

or statistics. The professional judgment of experts in a series of

balanced peer-consensus groups is used to bridge the technology

gaps.

89
d. In general, the evaluation system Is limited to evaluating the

interrelationships of those fire safety methodologies and approaches

that are defined in the Life Safety Code. There is no basis in the

system for accommodating completely innovative approaches (such as

automatic venting at the point of fire or the use of halogenated

gases as a general protection system) for which equivalency with the

Life Safety Code cannot be determined.

e. While the parameter measurements of the system cover built-in

structural materials and elements, space arrangement, and fire

protection systems and devices, the system does not permit alternate

approaches to meeting the Life Safety Code requirements for:

(1) Utilities such as heating, air conditioning, electrical, and

incinerator systems.

(2) Furnishings such as draperies, curtains, wastebaskets , and

beds.

(3) Administrative activities such as emergency plans and fire

drills.

When using the evaluation system, the existing requirements in these

three areas are applied in the traditional manner of explicit

conformance with the established standards and requirements as

described and/or referenced in the Life Safety Code.

The logic of the system is that the level of risk imposed upon persons

in a facility must be met by a system of safeguards that provides

sufficient safety to protect against that risk, using several

interacting but separate design approaches.

The evaluation is made on a

" FIRE/ SMOKE ZONE" basis. This is in

recognition of both the history of fires in health care facilities and

the traditional arrangements of patient care areas. The evaluation of

fire safety is relevant both to the capability of patients surviving

fire initiated in such a unit, and to the ability of the unit to exclude

the impact of fires external to it. The term "fire/smoke zone" is

defined as a space separated from all other spaces by floors, and horizontal exits or smoke barriers. Where a floor is not subdivided by

horizontal exits or smoke barriers, the entire floor is the zone.

The evaluation system applies this logic to each patient use fire/smoke

zone through the following steps,

a. Measure RISK .

b. Measure overall (GENERAL) level of safety.

c. Measure depth (redundancy) of safeguards in terms of:

90
(1) Fire CONTAINMENT capabilities.

(2) EXTINGUISHMENT , suppression, and control capablltles.

(3) PEOPLE MOVEMENT and other occupant protective features.

d. Determine equivalency to the prescribed requirements of the Life

Safety Code. Equivalency occurs when the values as measured by this

system are such that:

(1) The GENERAL safety level equals or exceeds the occupancy RISK

level, and

(2) The CONTAINMENT , EXTINGUISHMENT and PEOPLE MOVEMENT safety

levels each independently equals or exceeds the minimum value

corresponding to the level of that category required by the

Life Safety Code.

In establishing a system for evaluating risk, it is recognized that

there is a basic level of fire risk inherent in every health care

facility. It is also recognized that the amount of furniture,

equipment, and supplies (plus the arrangement of these within the space

available) depends on the occupant and is not quantified in the safety

equivalency measurement. The evaluation system baseline for occupancy

risk rests on the assumption that the furniture, equipment, and supplies

will be combustible, most adversely located from a fire-safety standpoint, and typical of those normally found in health care facilities.

Facility furniture could be expected to vary ad hoc so they cannot be

considered as known in a system analysis.

The factors used to judge the variations in fire risk are given in

Table 1 of the evaluation form. They are applied to individual

fire/smoke zones and cover the following risk controlling parameters:

the number of patients in the zone, their degree of mobility, their

average age, the ratio of patients to attendants, and the height of the

zone above street level. These five specific occupancy risk parameters

were initially chosen based on the experience and judgment of selected

members of the staff of the Fire Safety Engineering Division, Center for

Fire Research, and because they are considered to represent the

occupancy variables that control the risk in health care facilities.

The assessment of the specific parameters and the determination of their

relative importance was also based on judgment, plus the exercising of

the system on test cases to reveal inconsistencies or deviations from

accepted safety practice. (See Figure 1.)

The occupancy risk factor for any health care building is the product

of five individual risk parameter factors based on the risk factor

values shown in the evaluation form.

The minimum risk conditions have been defined as: a zone containing

fewer than five patients, all of whom are of sufficient health to be

91
Figure 1: Fire Smoke Zone Evaluation Work Sheet for Health

Care Facilities

HRE/SMOKK 7.0NK* KVAM ATION WORK SHKKT KOR HKAI.TH ( ARK l- A( II.ITIKS KACIIIIY Bl)ll.l)IN<i ZONE<.S) F.VAI.DATEI) FVAI IIA10R DAI F. Compieie (his work dieet for each /one. Where condilionk are the kame in Mvcral 7one%. one work <>hcet can be uied for Ihoie /one*.

Slep I: Iktermine (kxupucy Rnk Pirainclcr KacltirN I V liiMr I. A Kir each Rnk Pirameter in I able I. idect ami circle the appriipnalc rnk laclurvuluc ChiKnciinK tine lor each ol the

Tivc Rnk Panunetcf«.

TaWi 1. OCCUPANCY RISK PARMKTEI FACTORS

IISK PAIUKTEK MSK FACTM VUKS

1 MTKNT

MOMITT |R|

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STATtS MMIE INUTEi UlllITT NT

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PATKNT 15 1 tl 11 31 31 MM FACTH 1 1 17 IS 21

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4 IITIO OF PATKNTS TO ATTENOINTS |T|

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ATTENDANT

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i mm 1 icr 1 Vlitl IS UIIS

1 1 HI IHI 1 TCAI

IS fctis 1 ini

1 TUI I TOIKEI

kti iti II 1.2

IKK FICTOI Of 4 0 IS CHAISH TO Ml 20NE THAT HOUSfS PATKHTS WITHOUT ANT STAFF IN IMMCOIATE ATTFNOAHa

Step 2: Compute Occupancy Risk Factor (F) - Um Table 2. A. Traaafcr the circled rirt (actor value* frora TaMe I to the correaponding blocfci in Table I . Compute F by muhiplyiRt the risk factor valuet m indicated in Table Z

Table 2. OCCUPANCY RtSK FACTOR CALCULATION

M D L T A F OCCUPANCY RISK Q x

|

| x =

| |

Step 3: Compute Adjuned Building Statu (R) - (lie Table 3A or }B. A. If building i> claiuricd at NEW me TaMe 3A. If building is cianiricd as existing uae Table 3B.

n. Transfer the value of F from TaMe 2 lo laWe 3A or TaMe 38 as appropriate. Calculate -R." C Transfer -R" lo ihe Mock Ubeled "R" in Table 7 on page 4 of ihe work sheet

Tails 3A. (NEW BUILDINGS) Takle 3B. (EXISTING BUILDINGS)

' •=

*FIIE/$iORE ZONE is a spaci siparated trin all itkir spacis If floirs, hiiizontal eiits. ei smoke bimets

92
Figure 1 (continued)

Step 4: Delermine Safety Parameter Values - Use Table 4.

A. Selea and circle the safety value for each safety paraineter in Table 4 that best describes the conditions in the zone. Choose only one value for each of the 13 parameters. If two or more appear to apply choose the one with the lowest

print value

Table 4. SAFETY PARAMETERS VALUES

PARAMETERS PARAMETERS VALUES

1. CONSTRUCTION

COMBUSTIBLE NON COMBUSTIBLE

FLOOR OF ZONE UNPDOIECTEO PROTECTED

FIRST -2

SECOND -7

THIRD

4TH t ABOVE

UNPROTECTED PROTECTED -2

-4

-9

-7

UNPROTECTED PROTECTED FIRE RESIST

2. INTERIOR FINISN

ICorr. I Eiitj

CltSS s

3. INTERIOR FINISH IRoomsj

4 CORRIDOR

PARTITIONS/WALLS

NeilE OR INCOMPUTE

.1/3 »R

-10 lor 1 101 2 161

•

5. OOORS TO CORRIOOR

NO DOOR .70 m» FR ( AUTO ClOS

2 Id*"

6. ZONE DIMENSIONS

OEM END MORE TH«N mo

DEtO END

30 -100 W DUD ENDS '30 ( iONE lENGTH IS

-6 |0|" -4 101 -2

100-150

7. VERTICAL OPENINGS

OPEN 4 OR MORE

FLOORS

OPEN 2 OR 3 FLOORS

ENCLOSED WITH INOICtlEO FIRE RESIST

-14 2 101 3 101

OOUtlE OEFICIENCT SINGLE OEFICIENO

8 HAZARDOUS AREAS

OUTSIDE ;ONE

-6

IN UltCENT ;ONE NO DEFICIENCIES

SMOKE PtRTITION MECH ASSIST WSYSIEMS

9. SMOKE CONTROL

10 EMERGENCY MOVEMENT

ROUTES

MULTIPLE ROUTES

DEflCttNT CAPACITY W/0 HORIZONTAL

EAIT s HORIZONTAL EXIT S DIRECT EXIT s

11. MANUAL FIRE ALARM

NO MANUAL FIRE ALARM MANUAL FIRE ALARM W/0 F 0 CONN

12. SMOKE DETECTION

& ALARM

CORRIDOR ONLY CORRIDOR t

HABIT SPACE

13. AUTOMATIC

SPRINKLERS

CORRIDOR I HABIT SPACE

2 lor 10

NOTE * Use |0| when Item J ••Use |0| ulieii item I •••Use |0| in zone »illi

in eiistini biiililin(s

IS -10

0 IS -8

less lliin 31 patients

'Use |0| when item I is biseil on liisl flooi zone oi on in unpiolected type ol construction •Use |0| when item I is based on an unpiotecleil type ol consliuction •Use |0| when item 4 is -10

93
Figure 1 (continued)

Sicp S: Compute Individual Safety Evaluations - Use Table S.

A. Transfer each of the 13 circled Safely Parameter Value from Table 4 lo ever) unshaded blocks in the hne with the cor- responding Safety Parameter in Table 5. For Safely Parameter 13 (Sprinklers) the value entered in the (People Movement Safety) is recorded in Table S as 1,2 the corresponding value circled in Table 4.

B. Add the four columns, keeping in mind that any negative numbers deduct.

C. Transfer the resulting total values for S| . S:. Si. S<i lo the blocks labeled S| . S:. S i. S<i in Table 7 on page 4 of this sheet.

Table 5. INDIVIDUAL SAFETY EVALUATIONS

SAFETY

PARAMETERS

CONTAINMENT

SAFETY

ISll

EXTINGUISHMENT

SAFETY

|S2l

PEOPLE

MOVEMENT

SAFETY lS3i

GENERAL

SAFETY

(SGl

1. CONSTRUCTION

2. INTERIOR FINISH

(Corr. & {xit]

3. INTERIOR FINISH (Rooms)

4. CORRIDOR

PAIiTITIONS/WALlS

5. DOORS TO

CORRIDOR

6. ZONE DIMENSIONS

7. VERTICAL 0PENIN6S

8. HAZARDOUS AREAS

9. SMOKE CONTROL

10. EMERGENCY

MOVEMENT ROUTES

11. MANUAL FIRE ALARM

12. SMOKE DETECTION & ALARM

13. AUTOMATIC

SPRINKLERS ^ 2

TOTAL VALUE S2 =

94
Figure 1 (continued)

step 6 Itelcnninr Mandmory Siroy Rettuitcmcm Values • Uk Tabk 6. A Csing ihedauiricaiion ofihc building (i.e.. Nc« or Exiniiii) and Ihe floor where the /one a located, drdc Ihe appropiralc value in each t>f the three columnt in Table 6. H I ransfer the three circled values from Table 6 to the blocki marfccd St. Sk. and Sc in Tabic 7.

Table 6 MANDATORY SAFETY REQUIREMENTS

CONTAINMENT SaEXTINGUISHMENT SbPEOPU MOVEMENT

St

ZONE LOCATION New Exist. Ne« Exist. New Exist.

FIRST FLOOR 9.0 4il 60 3.0 6.0 1.0

ABOVE FIRST FLOOR 140 8.0 80 50 9.0 3.0

Step 7: Fvaluation Fire .Safety Eijuivaleiicy - Uk Table 7.

A. Perform the indicated tublractions in Table 7. Enter the dincicnca in the appropriate answer blocks.

B. Foreachrowcheck'Yes'ifthevahicintheaniwerblockisKroorvcater. Check '^o* if the value in the anavcr Mock

is ajKfativc number.

Table 7. ZONE SAFETY EQUIVALENCY EVALUATION YES NO

CONTAINMENT MANDATORY

SAFETY (Si) CONTAINMENT (Sal ^"

Si Sa C -:!]=

EXTINGUISHMENT , MANDATORY >•

SAFETY ($2) EXTINGUISHMENT (Sb)

S? Sb I

PEOPLE MANDATORY

MOVEMENT,. , less PEOPLE iO

SAFETY 1S3) MOVEMENT (Sc)

S3 Sc P

GENERAL , OCCUPANCY

SAFETY (Sg) RISK (R|

Sc R 6

CONCLUSIONS:

I [ ) All of the checks in Table 7 are in the "Yes' column The level of flie safety is at least equivalent to that preacribad by

the Ijfe Safety Code*

2. ( I OneormoreofihechecksinT«ble7atcinthe''N<rcoiumn. ThclevelorrircaafetyisnolshawnbylhissyMcroiobe

equivalent to that prescribed by the Life Safety Code.* *The equivalency covered by this worksheet uicludes the majority of considerations cowered by the Life Safely Code. The re

are a few considerations that arc not evaluated by (his method. These must be separately coiiaidcrcd. These additional considerations are covered in the "Kadliiy Fire .Safety Requirements Worksheet .' One copy of this separate worksheet is to be completed for each facility.

I his form has been prepared by the Kire Safety Engineering Division. Center for Fire Rctearch. NBS. as part of

the HKW NBS l.ife Safely Fire Safely project. June 27. 1977 Reviled March 15. I97K

95
considered fully mobile and capable of evacuating themselves, their

average age being less than 65 and over one; a ratio of patients to

attendants of 2:1 or less; and the zone located on the first floor of

the building. This condition is assigned an occupancy risk factor of

1.1.

In contrast, the conditions evaluated as representing the upper range of

risk as contemplated by the Life Safety Code are based on: more than 30

patients in the zone, all of whom are unable to move without assistance;

their average age is over 65 or under one; a ratio of patients to

attendants of 10:1 or more; and the zone located above the sixth floor

or in the basement. This was assigned an occupancy risk factor of 18.

Greater risk values are assigned to patients who cannot be moved and to

fire zones which are unstaffed. The maximum possible risk has a factor

of 69.

The general safety factors are measures of those building and fire

protection features that bear upon the safety of patients (and other

occupants) who may be in the particular fire/smoke zone at the time of

a fire.

The safety parameters were selected by examining the specific code

element requirements for health care facilities, Chapters 10 and 17 of

the 1973 Life Safety Code, and by evaluating the impact of various

elements of the Code. The selected safety parameters were modified

first by the NBS Delphi panel and later by the consultant groups.

Each of the safety parameters was analyzed. Where the current Code

requirements recognized several different levels of a parameter (e.g.

the Life Safety Code recognizes eight different types of construction)

the most important alternatives were listed. In addition, conditions

likely to be encountered in situations failing to meet the explicit Code

requirements, and conditions exceeding those required by the Code but

available for increased protection, were also listed. Table 4 of the

evaluation form shows the final "matrix" form of the breakdown of the

13 selected safety parameters, each having three to seven subdivisions.

(See Figure 1.)

The safety parameters are designed to constitute a complete assembly of

all of the basic building factors determining the level of safety in a

health care facility for which equivalency could be expressed. In

addition, we collected and attached to the inspection form an additional

series of items required by the Life Safety Code but outside the scope

of the equivalency covered by the listed safety parameters. These

relate primarily to building utilities, operational features and

furnishings, and they are listed in the separate Facility Fire Safety

Requirements Worksheet that accompanies the evaluation form. (See

Figure 2.)

In order to provide a method bringing the best available consensus

judgment and experience together to judge the relative impact on general

96
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97
safety of each of the parameters in each of the potential conditions

listed, a Delphi type peer group was established. This peer group

consisted of members of the Fire Safety Engineering Division, Center

for Fire Research, NBS, with the greatest background and experience in

the application of fire protection engineering principles and practices

to buildings.

Each member of the group was provided with copies of the initial matrix

similar to the one shown in Table 4 of the form, but without numerical

parameter values. Each person then evaluated the relative importance of

each item in the entire matrix of parameters without consultation with

other members of the group. The members of the Delphi group were

advised that the risk being considered covered new and existing health

care facilities and that the objective was a system to measure equivalency with the 1973 Safety Code. The value judgments made by this group

are, therefore, considered to be based on the character and needs of

patients in health care facilities and the current approach to these

embodied in the Life Safety Code. In addition, each member of the group

evaluated separately the same matrix in relation to the redundant

subsystems. In executing the matrix, each peer group member was

requested td assign a value of +10 to that safety parameter element (or

level) considered to be the single most important to safety to life and

to compare all other elements in the matrix to that base. A zero value

represented a neutral condition; i.e. a safety parameter at this level

would not increase or decrease the safety conditions of a fire zone.

Negative values represented deficiencies, i.e. safety parameters at this

level decreased the safety conditions of a fire/smoke zone.

After an initial analysis of the results, the peer group was asked to

meet in conference on several occasions. The peer group on those

occasions deviated from the traditional Delphi approach but instead

reviewed differences and concepts, with a view to achieving consensus

agreement on categories and on selection of the numerical values.

Several categories were modified and qualified. A significant

adjustment was to shift the numbers so that a baseline would be

established in which negative charges would not be made against any

general safety parameter that was in explicit conformity with the

requirements of the 1973 Life Safety Code.

The relationship between the safety parameter values and the code

requirements was established by summing the value of all of the credits

and deficits of the safety parameter elements for a health care facility

that exactly met all of the requirements prescribed by the 1973 Life

Safety Code. Attempts to do this disclosed that the Life Safety Code

actually had eleven sets of requirements, seven for sprinklered

facilities and four for non-sprinklered facilities. Based on the

relative value of protection methodologies developed by the Delphi group

and refined by the review process described later in this report, the

levels of safety prescribed by these requirements are:

98
General Safety Value Required

Non-Sprinklered

Buildings

Sprlnklered

Buildings

1 . New buildings 1-story

In height.

2. New buildings over

1-story In height.

3. Existing buildings

1-story In height.

4. Existing buildings over

1-story In height. 9 16(b)

18

13

9

5

23(a)

16

16(b)

8

(a) 20 for 2- or 3-story buildings.

(b) 14 for 3-story and 10 for 2-story buildings.

These values represent the level of general safety required by the 1973

Life Safety Code to house health eare occupants In the class and height

of building Indicated. The analysis demonstrates that, In terms of the

values In the evaluation system, the Life Safety Code minimum requirements are those for non-sprlnklered buildings. The highest total value

developed for a non-sprlnklered building Is 18. The Importance of this

value Is that It was used as the approximate baseline for the establishment of measurement of risk In a multi-story building and Is the

principal balance point for comparing occupancy risk with general

safety. Thirteen Is the comparable value for a single story building.

The values for existing buildings demonstrate the reduced level of

general safety accepted by the Life Safety Code for these buildings.

For a one-story building, the general safety value Is +13 for a new

building and +5 for an existing building. Indicating that for an

existing one-story building only 38% of the score expected of a new

one-story building Is required. Similarly, the ratio of existing

multi-story buildings to that for new multi-story buildings Is 1/2.

The 0.5 factor In Table 3B of the Fire/Smoke Zone Evaluation work sheet

reflects this ratio. (See Figure 1.)

A basic principal of the Life Safety Code is that there will be a

redundancy of protection so that the failure of a single protection

device or method will not result In a major failure of the entire safety

system. In addition, the development of a redundant approach, as used

In this safety evaluation system, avoids the pitfall of traditional

approaches to developing grading systems where all of the elements are

considered mutually exclusive of each other and a single total score

determines acceptability. Under such a system. It Is possible to

completely disguise the absence of a critical element. The evaluation

system establishes redundancy on the basis of In-depth coverage of the

principal fire safety methodologies. The redundant methodologies used

99
in the system are those related to fire safety through containment,

through extinguishment, and through people movement (including refuge).

The redundant methodologies were chosen after examination of decision

tree approaches. These divide fire protection by element. Four

different methodologies of managing fire impact were identified. These

are control of the fuel and arrangement; compartmentation and other

mechanisms of containment of the fire and its impact; extinguishment,

suppression and other means of terminating fire development; and the

provision of safe locations of refuge either by evacuation or by

establishment of safe areas of refuge. Those elements related to the

control of fuel and its arrangement are incorporated into the risk

analysis portion, in terms of the occupancy risk baseline. Therefore,

only three redundant methodologies were used in the analysis.

As part of the initial Delphi exercise, each member of the Delphi group

completed a matrix establishing his judgment on the relative importance

of the items in the general safety parameter matrix, he also made

additional judgments on the same matrix elements related to the separate

fire safety methodologies of containment, extinguishment, and people

movement. These were then processed, and analyzed and reviewed in

subsequent conference meetings of the Delphi group. By this process,

the parameters that have a significant impact on each of the redundant

methodologies were identified. Many of the parameters impact on more

than one of the methodologies. In the judgment of the group only

sprinkler protection impacts on all three. Table 5 of the evaluation

form shows the breakdown in terms of which parameters apply to which

methodologies, (See Figure 1.)

Each of these subsystems was then evaluated to determine the point value

that would result from explicit compliance with the requirements of the

Life Safety Code for that subsystem. Because of the variance between

new and existing buildings and between single story and multi-story type

buildings, four values were determined for each of the redundant safety

methodologies.

In this fire safety evaluation system, these values are mandatory

minimum values that must be met regardless of the overall evaluated

level of occupancy risk or the overall evaluated level of general

safety.

This evaluation system determines the efficacy of any arrangement of

the listed fire safety subsystem elements in a fire/smoke zone by

considering the risk factors and safety parameters relative to the

level of safety that would be achieved by explicit conformance with the

specific requirement of the Life Safety Code (NFPA 101-1973), To be

determined as equivalent, the measurement must demonstrate that:

a. The general safety level produces a value that equals or exceeds

the determined value or charge for risk.

J 100
b. Each of the three individual redundancy groupings (containment

safety; extinguishment safety; and people movement safety) must have

an arrangement of safeguards that meet the prescribed minimum for

that redundant grouping independent of the other condition.

All of the parameters, variables and formulas for determining the

facility safety equivalency with the Life Safety Code are contained in

a self-instructing form. A separate manual has been prepared to assist

in completion of the evaluation form* The manual provides expanded

discussions and definitions of various items in the evaluation sheet to

assist the surveyor or reviewer when questions of definitions,

interpretations, or meanings arise. To evaluate totally a health care

facility, it is necessary to evaluate each of the different fire/smoke

zones.

The evaluation system has a theoretical capability of evaluating about

230 million combinations of the 13 safety parameters and variations.

Practical arrangements in existing buildings and future design are of

the order of a few thousand. For the purpose of verifying the original

proposed system, as well as to analyze potential proposed changes, a

computer program was developed. The program generates all arrangements

that are valid, based on data given for the safety parameters. Using

the Fire Safety Evaluation Worksheet, an experienced engineer or facility

can manually analyze 10 to 15 differently organized zones, and establish

the most suitable configuration for the facility. By using the computer

program, the evaluator is able to review all posible solutions to his

problem, and he can also be assured that answers are not biased by

individual preference. The printouts of the zone arrangements can be

easily analyzed by an experienced individual to estabish equivalency of

solutions.

An effort has been made to make the system consistent with accepted and

sound fire protection engineering practice and theory. While the most

advanced scientific knowledge has been used in developing the system,

the state-of-the-art requires that the insight and professional judgment

of experts in the field serve as the base for information in developing

the system, and the available technical knowledge (including results of

fire tests, statistical analyses, fire investigations, etc) serves a

supportive role. In the development of the fire safety evaluation

system, therefore, both the NBS Delphi group and the professional

consulting panel were selected on the basis of expertise and interest.

In the systems proofing effort, the capacity of these panels was

broadened by using a two-step judgment approach. In the first step the

relative worth of each parameter was individually judged on its

relationship to other parameters. This evaluation was made in terms of

each parameter's contribution to both general safety and to each of the

redundant safety requirements. In the second phase, the parameter

values, developed in the preceding phase, were applied to a large number

of test cases, scenarios and reviews of specific facilities. The

resulting fire safety system configurations were then judged on overall

101
equivalency to configurations prescribed by the 1973 Life Safety Code.

This process provided a balance and cross-check between judgments of the

value of the individual parameters and evaluations of the overall product.

Throughout the project, the project staff maintained liaison and a flow

through the described review groups and a recently established task group

of the National Fire Protection Association Committee on Safety to Life.

This task group is studying the evaluation system for inclusion in the

NFPA Life Safety Code.

The conclusions resulting from this study are briefly stated as follows:

a. A methodology has been developed and described for generating

equivalency to a specified set of occupancy safety requirements. It

is based on the understanding of level of occupancy risk, building

safety, and redundancy of safeguards. This methodology can provide

the necessary flexibility for a designer to achieve minimum cost

solutions for a specified level of safety.

b. The described methodology, "System for Fire Safety Evaluation of

Health Care Facilities," is a specific example of an equivalency

approach. The system provides equivalency to the minimum life

requirements for the health care facility, as prescribed by Life

Safety Code 101-1973. The system can be updated for later Life

Safety Code editions for health care facilities.

c. Other equivalency systems can be developed for other occupancies,

but this will require detailed analysis of the risk level, the

variety of building safety requirements, the necessary redundance

equations, and other aspects of the specific occupancy involved.

102
Rehabilitation Standards: What Are They?

Who is to Develop, Maintain, and Enforce Them?

by

Bernard A. Cummings

National Association of

Housing and Redevelopment Officials

Mr. Cummings holds a B.S. in Environmental Health and a Master of Public

Mr. Cummings has 27 years of experience

in housing code enforcement, neighborhood

conservation and housing rehabilitation

in the cities of Pasadena, Oakland and

San Francisco, California.

Mr. Cummings is the Assistant Superintendent of the Bureau of Inspection and

Secretary of the Abatement Appeals Board

of the City and County of San Francisco.

In addition, he is currently the Chairman

of the Codes and Standards Subcommittee

of the Conservation and Rehabilitation

Committee, National Association of Housing

and Redevelopment Officials.

Those of you who are building officials know what the bible for construction

is—your building code. Those of you who have housing codes know this is

the bible of rehabilitation. This is the San Francisco housing code. It

is a very small document. In addition, you have field inspection manuals

that give you equivalents, explanations on how to apply the codes to the

gray areas in existing buildings. And, then you have maybe a 4- inch

thick document of administrative bulletins and code rulings which go into

the details of day-to-day decision-making by the building official in the

solving of particular problems as they arise.

The reason I am here is that I represent the National Association of

Housing and Redevelopment Officials (NAHRO) . NAHRO is an organization

involving people in the fields of redevelopment, public housing and

community development and rehabilitation, with many of their agencies

103
involved in Federally-financed rehabilitation. NAHRO's concern is with

the model code groups. We wondered how the impediments to conserving

our existing buildings could be removed from the model codes. I think

we are being told we are on the way to seeing these impediments removed

and that the model code groups are interested and committed to removing

them.

The particular contribution I made to the Massachusetts proposal is the

field inspection manual. You will see in some of its sections certain

equivalents or solutions to problems where alternatives are acceptable

depending on the condition that you find in a particular building.

T\7enty years ago, in 1958, the city of San Francisco adopted its housing

code. I think there are about 1,000 communities in the United States

that adopted housing codes as part of the workable program, a former

Federal requirement for receiving Federal funds for redevelopment and

other U.S. Department of Housing and Urban Development (HUD) programs.

Many of these cities had no housing code. San Francisco adopted its own

housing code, although the State of California had a State housing act

that went back to 1923. The problem with working with a housing code in

dealing with rehabilitation on a building-by-building, block-by-block

basis, is how to deal with the variety of conditions that you run into

that are not covered in any code.

How do you apply the retro-active provisions of the code? To solve this,

in 1957, we adopted our first field inspection manual. How did we do

it? We had our first designated conservation area in 1959. We spent the

first six months going through buildings and inspecting them, bringing

in all the various experts from the various departments involved in code

standards, such as the zoning ordinance, the fire code, health, building,

plumbing and electrical codes, and the housing codes. Working together,

walking through buildings, we tried to determine solutions to code problems to allow us to retain these buildings. In San Francisco, we had a

very tight housing market 20 years ago. We still do.

This first conservation area was an area that had large mansions that had

been converted to rooming houses and boarding houses, and there was a

great need for that type of housing for single individuals, low income

people, and students. How do you retain these buildings? What do you do

to make a boarding house or rooming house comply with the building code

requirement for a hotel? Most of these buildings had been converted

illegally; i.e., had been converted without a permit. So, the philosophy

was developed in that first six months that you accepted the building as

it was originally built and you required it to at least meet the requirements at the date of the conversion.

The idea was not to penalize the property owners for someone else in the

past not having taken out a permit if, at that time, the use could have been

allowed. Whatever that use was or whatever materials were used, those

materials were acceptable 20 years ago; thus, they would be acceptable

104
today. Simply because someone had not taken out a piece of paper and

paid a fee was not grounds for not accepting the existing condition.

That was the basic philosophy; to retain and legalize.

We developed the manual following the logic of going through the building. First going through the yards and courts, fences, retaining walls,

and patios, and then through the buildings from the foundations and wood

floors to the roof. We researched the requirements in room dimensions

at different periods of time. In 1906, a 7 '2" ceiling height was a

requirement of a code. In 1910, it was 7 '6". At different periods of

time there were different code requirements. These earlier requirements

whatever they were, are acceptable today. The use existed at that time.

How do you achieve equivalency in safety? As the time has gone on, this

field inspection manual has been revised, repeatedly, continuously. Our

housing code has been revised. Many of the conditions that were originally

covered by our field inspection manual were later adopted into the housing

code so that the policy is very clearly set forth in the housing code on

what you do with existing buildings. This is the law of the City of

San Francisco concerning existing buildings. It is not an administrative

bulletin anymore or a field inspection manual that was developed to guide

the instructors, it is now part of the code.

In the building code there are several sections that have to do with

existing buildings. They address how you treat existing buildings and

how you convert existing buildings. You have a matrix, as was described

by the previous speaker. It is located in Section 501 of the San Francisco

building code, which describes the uses of buildings that you can convert

from to another less hazardous use, without providing additional requirements to meet today's new construction codes. So, you can go from one

use to another use, and not provide any additional requirements to meet

today's new construction standards in converting the use of a building,

like a warehouse to an office building, as an example.

There are certain things that you do have to provide that have to do with

life safety, and in San Francisco one of those conditions is seismic

safety. We are in an earthquake prone area and have to look at the seismic resistance of the building. So, in the building code we cover existing

buildings, we talk about conversion and new construction. In our housing

code, we talk about existing residential buildings. In our field inspection manual we talk about the solutions to problems that you run into in

the field, so that the inspector knows how to recognize and deal with the

gray areas of what is the code requirement and what is acceptable at less

than code, and at what point you may have to go to an appeals board.

There are several appeals boards in San Francisco. We have a board of

examiners which is made up of representatives of professional organizations;

the engineers, architects and so forth. They review design problems.

Several years ago a cathedral was built in San Francisco. The concept of

its design had never been used before and the codes certainly could not

handle this type of building. Wind tests and all sorts of other tests had

105
to be carried out to establish, to the satisfaction of this board of

examiners, that the design of this building could withstand various

conditions including seismic which might impair its safety. This has

been the approach we have used in San Francisco over the last 20 years

and it now appears that this is the approach Massachusetts is planning

to follow.

From what we have heard from the previous speakers, there is nothing

magic about this approach, it can be done. However, It does require

a competent trained staff. This is where I am concerned. I believe we

should all be concerned with where we are going to get the people who

are going to be able to deal with this systems analysis approach to code

enforcement—someone who can determine whether a particular system of

exitways is going to work if smoke detectors, heat detectors, sprinkler

systems, stairway enclosures, smoke barriers and/or some combination

thereof is installed. The people who are going to have to make these

decisions—your inspectors—have to be competent, they have to be trained

and there has to be a continuing mechanism for this.

These codes, field inspection manuals, administrative bulletins and code

rulings require regular revision and updating. Where is this going to

occur? How do these decisions that are reached in the field get to the

Administrator so that they will be in writing, where everyone is aware

what is an acceptable alternative, and is there a method for it to be

passed on to others who are faced with this same problem? In the City

and County of San Francisco we have this mechanism, but how do we do it

on a national basis? Thus, training, competent staff, adequate pay, are

the problems we hear about in talking to our co-workers in NAHRO about

nepotism and the incompetent people they run into in the codes field. The

quality of the inspectors who are given this responsibility is very

important to avoid the payoffs and the kick-backs. In Chicago 20 years

ago you needed seven or eight people to make an inspection so that the

payoff would be too large for the property owner. We saw the same thing

again in Chicago on "60 Minutes," just last year. So, things have not

changed that much in 20 years.

And, you know, the real world is out there. Where are these people coming

from, where is this professionalism going to come from and how is this

system going to be kept up-to-date on a continuing basis?

106
PANEL DISCUSSION

QUESTION ; James H. Pielert, National Bureau of Standards (NBS)

How are your housing code and inspection manual revised?

What is the input of the professionals in the area? Is

it done by your department? What is the mechanism?

RESPONSE ; Bernard Cummings, National Association of Housing and

Redevelopment Officials (NAHRO)

The latest version of our field inspection manual is dated

August 1978, and here we are several months later trying to

get it out to all the people who use it. This is done by

committee. The Chief of the Division of Apartment House and

Hotel Inspection, the Chief of the Plumbing Division, the

Chief of the Electrical Division, the Chief of our Abatement

Section, the Chief of our Rehabilitation Assistance Program,

and the Chief of our District Building Inspectors, work together as a team and go over it item-by-item, page-by-page.

People are submitting changes and suggested changes to the

field inspection manual and the housing code based on problems

they see, through a regular process of filling out a form and

submitting it to the Superintendent's Office, and these are

accumulating. Ideas are coming up, problems are coming up,

solutions are coming up all the time. How do you get these

into the system for discussion?

There are discussions going on of all sorts. As Mr. Lewis

mentioned about the inspectors quarrelling with each other;

well, this does happen. I do not think we have ever completely

gotten our plumbing inspectors and electrical inspectors in

line with the philosophy of not trying to sell complete electrical or plumbing jobs when only a minimum amount of work is

necessary to correct the problem if the intent of the code is

followed. And so, it is a team effort. It goes up through a

process of review and it takes months of doing and it is a

continuing thing. And, it is required that the codes have to

be updated every three years.

QUESTION ; James H. Pielert, NBS

Mr. Nelson, would you like to say a few words about the status

of the work you are doing for the U.S. Department of Housing

and Urban Development (HUD) on the minimum property standards?

107
RESPONSE ; Harold E. Nelson, NBS

We are just beginning. What we have done to-date is twofold. One, we extended the matrix of safety items to a

broader consideration. It has been sent to all 70 HUD Offices and each was asked to circle every one that it ever

uses. We expect to find some that never get applied and

we do not expect to get answers from every office. Secondly,

we took the same matrix of elements and then we put across

the top of the matrix the bottom inputs of a typical fire

safety decision tree.

What we are in the process of doing is attempting to analyze

the code. First of all, to say, what pieces of code hardware

deliver what elements of fire safety and which pieces of code

hardware deliver multiple elements, and then to mark it in

such a way that the level of requirement is shown. We hope

to get on one sheet of paper a complete description of a code

which would be kind of nice to work with. It is using the

matrix system.

Actually, when you go through a building and you mark it on

that evaluation system and you circle the thirteen items that

apply, it is amazing how complete a description you have of

a code of a building right in front of you, as far as this

problem area goes. We also expect to see this trade-off

matrix. If you are attempting to maintain equality and you

start playing with a piece of hardware or a requirement, it

would be very nice to know where that piece of hardware impacted on which elements of safety so that when you replaced

it you could be sure that your replacement covered all those

same elements. Or, conversely , if somebody had an especially

good thing in the building and wanted to know if he could get

credit for it, you could show him in which areas it applied.

So we think it is useful. But beyond that, that is our stage.

We will be moving into the development of a matrix and then

gathering together the experts and the oracles that we will

use to help us assign the numbers.

QUESTION ; Ben Brungraber, B and B Engineered Timber

In the past I have been a building inspector, a pretty underpaid, imappreciated field, and I do not see any potential

building inspectors in the audience. I wonder if Mr. Cummings

would address the situation. We seem to be going to fancier,

more explicit codes and equations among other things, and it

seems that they are taking all the decision-making out of it.

We are trying to keep everybody covered so we do not get sued.

I wonder if another way to go about it might be to just establish guidelines and pay inspectors and let them make their own

decisions and be creative, and get people willing to make

decisions.

108
RESPONSE: Bernard Cummings, NAHRO

I know that paying Inspectors properly is very important.

I remember 20 years ago telling our superintendent building

inspector about an article in House and Home magazine about

the building inspectors in Oklahoma City who could not

afford to buy a house in Oklahoma City—the buildings that

they were inspecting. I thought this was a good excuse of

why we should be doing something better in San Francisco.

When we held an examination for building inspectors, we

received 250 applications and ended up with 20 who were on

the civil service list. They were registered architects,

licensed engineers, and general contractors, and we are talking about $25,000 or maybe $30,000 a year, including fringe

benefits. You are not going to attract anyone from the

private sector. They can do much better out there.

COMMENT ; Ben Brungraber, B and B Engineered Timber

It seems to be a problem in any code we have; they are only

as good as the people who go out and inspect them.

COMMENT ; Bernard Cummings, NAHRO

That is right!

COMMENT ; Walter Lewis, University of Illinois

The need for increasing the amount of remuneration that code

enforcement officials receive was the question, was it not?

COMMENT ; Ben Brungraber, B and B Engineered Timber

I am just curious about another philosophy I picture where,

instead of writing fancier codes to take away the responsibility

for decisions, set guidelines and hire some more creative

people who are willing to go out and do the inspections.

RESPONSE : Walter Lewis, University of Illinois

I think, legally, the code has to be written in language that

is vinderstandable. I think we are talking about a need for

competency on the part of those who design buildings and build

them, and an increased competency, in many places, on those

who enforce the provisions of the code. The one thing that I

would comment on is that the competency of those who are enforcing the code is a different level of competency than those

who are designing and building the buildings.

109
For instance, in the School of Architecture, we are teaching people about how to design a building that has to be

built. The code enforcement official does not need to build

buildings, does not have to construct buildings; however, the

code enforcement official does need the competency to determine that those who do build it or design it , do it according

to the law. At least we should be paying and attracting

those with competency who can do that job. In many cases, we

do not have the support of city councils, we do not have the

support of city managers, that is one of the reasons why;

although we need the technical back-up and capability, that is

one of the reasons we did what we did.

The city council has to appropriate more money. The city

manager has to believe that the building department and those

who are involved in code enforcement really are a part of

the community development and redevelopment team. I think

in many communities, that is not given the importance that it

should have.

COMMENT ; Bernard Cummings, NAHRO

I think one of the things that gives you some evidence of

community support is when you go to your city council or

board of supervisors for your fee adjustments. The Bureau of

Building Inspections in San Francisco is 100 percent selfsupporting through fees as of one month ago. Prior to that,

it was 70 percent self-supporting. Those fees were raised for

the first time in 10 years rather astronomically, yet the

industry, the Chamber of Commerce, the Apartment House Owners

Association, and all the others who are contractor's associations who are affected by those fees, felt that as long as

they were getting a service, they wanted the service and were

willing to pay for it. If they are satisfied with the service,

they will support the request.

COMMENT ; Ben Brungraber, B and B Engineered Timber

One of the differences between writing codes and enforcing

is - I just wonder if you compared how many people died in

fires because a staircase is two inches narrower than it

might be to the number who died because the fire exits are

locked to keep people from sneaking in the back doors of

night clubs. If you compared these two, I think we have

probably lost more from locked doors that should not have been

locked, and an inspector might have caught it if there had been

a more steady inspection.

110
Session on Administrative Procedures and Their Effectiveness

Moderator: William Plouffe, President

Charleswater Associates, Inc.

PANEL

Creighton Lederer Frederick A. Stahl Joseph Stein

Commissioner, City of Principal Principal

Detroit Perry, Dean, Stahl and Joseph Stein and

Department of Buildings Rogers, Architects Associates

and Safety Engineering

I

111

SESSION MODERATOR

William Plouffe

President, Charleswater Associates, Inc.

Mr. Plouffe received a S.B. in Mechanical

Engineering from the Massachusetts Institute

of Technology, and a M.B.A. from Harvard

Business School

.

As President of Charleswater Associates, Inc.,

a management consulting firm specializing in

studies of the impact of government regulations, directed many projects in the building

regulatory field including industrialized

housing, third-party inspection programs,

housing codes, energy codes for buildings

,

training of building and housing code officials and development of a statewide building code program.

As a consultant to the National Conference

of States on Building Codes and Standards,

serves as project coordinator for the pilot

program for the State of Massachusetts to

develop interim provisions for alterations

and additions to existing buildings

.

The topic of this session is Administrative Procedures and Their

Effectiveness, particularly as related to the rehabilitation code under

the pilot program for Massachusetts.

This program was started nearly a year ago when I made a brief survey of

selected building officials, sponsored by the National Bureau of Standards

(NBS), to determine first of all, is there a need for a special way of

handling the regulation of rehabilitation; and, secondly, what are the

characteristics of such special regulation? I see in the audience, several

building officials who I talked with in the course of this survey. The

point is, that the conclusions we will be reporting and discussing today

are the results of what you—the building of ficials—have told us. They

are not factors which the project team dreamed up.

113
Figure 1 is a sunnnary of our survey conclusions regarding the need for

a special way of regulating rehabilitation.

FIGURE 1: SUMMARY OF SURVEY CONCLUSIONS

IS THERE A NEED FOR A SPECIAL WAY OF HANDLING REGULATION OF REHAB?

REVIEW OF PAST ACTIVITIES AND RECENT SURVEY OF BUILDING AND REHAB

OFFICIALS INDICATES THAT THERE IS A NEED .

PERCEIVED NEED VARIES AMONG AREAS:

• Greatest in older areas with changing socio-economic patterns.

• Attitudes of community as reflected in code interpretation

• Impact of judicial decisions on building official liability and

limits to interpretative judgment.

BUT

ANY NEW REHAB REGULATORY SYSTEM:

• Must not add still more prescriptive rules

• Must increase flexibility of code interpretation

• Must provide interpretative guidelines to building officials

The team concluded from the survey that such a need did, indeed, exist.

This need, however, was not consistent throughout the country, and the

perceived need by building officials varied among various geographic areas

Some of the parameters which affected the perceived need included:

• The perceived need was greatest in older areas with changing

socio-economic patterns. In many geographic areas, older mill

buildings and waterfront warehouses are being turned into condominiums, apartments, retail and mixed-use buildings; schools

are being considered for other uses; old Victorian single-family

houses are being turned into apartments—this "adaptive re-use"

is limited only to the imagination of developers and architects

and changing market requirements for space.

• The perceived need for special rehab regulation is a function

of attitudes of the community as reflected in code interpretation. For example, it was reported that in California at one

stage of the development of some areas, the "50% rule" was used

to demolish buildings. The same concept was reported from

Massachusetts; when the city of Boston was made up primarily of

114
wood frame structures with great potential for conflagration,

the community desired to replace these structures for the

safety of the community. At present, even the older buildings

are primarily masonry construction, basically sound structurally,

and the community desires to preserve and utilize these

structures to the fullest extent.

• Another perceived need for encouraging special regulations and

procedures for rehab was the concern expressed by several building officials of their legal liability when interpretative

judgment is required. The need for judgment in interpreting code

requirements and determining the intent of the code is greater

for rehabilitation work than for new construction. Our respondents

indicated that judgment on the part of the building official is

currently being utilized in the field. Several instances were

pointed out, however, where when a building official did use judgment and did not necessarily enforce to prescriptive code

requirements, he was held personally liable for a resulting

accident

.

Our respondents also told us, however, that any rehab regulatory system

must have the following characteristics:

1. Must not add still more prescriptive rules;

2. Must increase flexibility of code interpretation; and,

3. Must provide interpretative guidelines to the building official.

In other words, the building officials told us not to add merely another

set of prescriptive-type standards—for example, an eight percent window

area requirement instead of ten percent. Interpretative judgment is

being used in the field now, but some method must be developed to

"institutionalize" this judgment and put it on a sound, rational basis

which can be consistently applied, recognizing, however, the uniqueness

of each structure in a rehab situation.

In general, the rehab code problem can be categorized into two main issues

as shown in Figure 2.

1. The first general problem is the documents themselves; e.g., the

codes, guidelines, standards, and technical manuals governing

rehabilitation.

2. The second general problem is the delivery system; e.g., the

agencies and personnel involved, legal problems, procedures and

community values as reflected in code interpretation.

Breaking down these two major categories led us to six major identifiable

problem areas as shown in Figure 3.

115
FIGURE 2: THE REHAB CODE PROBLEM

THE

DOCUMENT (S)

Code(s)

Guidelines

Technical Manuals

Standards

THE

DELIVERY

SYSTEM

Agencies

State-local-bldg-f ire-housing

Interagency cooperation

Personnel

Competency

Use of judgment, trade-offs

Fulfillment of code intent

Legal-Judicial Problems

Liability issues

Procedures

Appeals

Departmental (e.g., pre-permit

conference, agreement on

acceptable practice)

Community Values

FIGURE 3: PROBLEMS WITH CURRENT CODES RELATIVE TO REHABILITATION

1. Current Codes Represent New Construction

• Language and Structure Delineate the Construction Process

• Obsolete Constructions Replaced by More Modern Techniques

2. Requirements for Compliance Are Arbitrary

• Change of Occupancy - Complete Compliance

• 25% to 50%

3. Nature of Codes Limits Alternate Solutions

• Prescriptive Language

• Lack of Technical Basis to Approve Alternate Methods

4. Regulatory Organization and Procedures

• Multiplicity of Codes (Building, Plumbing, Electrical, etc.)

• Split Responsibility for Enforcement

5. Legal Problems with Alternate Solutions

• Court Decisions Have Tended to Discourage Judgment

on Trade-offs

6. Background and Skills of Enforcement Personnel

• Tend to Be Prescriptive-Oriented

116
First, current codes represent new construction. The language and the

structure delineate the construction process as opposed to an analytical

process which is generally required to analyze a rehabilitation situation.

Obsolete constructions, although perhaps suitable, are replaced by more

modem techniques in current codes.

The second item was that the requirements for compliance are arbitrary.

Of critical importance here is the traditional 25-50% rule, and the fact

that with a change of occupancy normally complete compliance with code is

required.

Three, the nature of codes limits alternate solutions. Once again, the

prescriptive language and secondly, the lack of a technical basis to approve alternate methods was cited as being more critical in rehabilitation

than for new construction.

The fourth is regulatory organizations and procedures. The multiplicity

of codes; building, pliunbing, electrical; and the split of responsibility

for enforcement, although also a problem in new construction, appears to

be a worse problem in rehabilitation. In new construction, somehow our

system, our private system of contractors, architects, and engineers has

managed to find ways of living with the multiplicity of codes and the

split responsibility for enforcement. However, when in a rehabilitation

situation the problem is more critical because it is difficult to know all

of the problems beforehand. When starting with an existing structure, the

problems may not be discovered until construction is actually started.

Hence, the problem of regulatory organizational structure seems to be worse

in rehabilitation than it is in new construction.

The fifth problem deals with the legal liability issues in approving alternate solutions. It was reported that court decisions have tended to

discourage judgment on trade-offs or alternate solutions, which tend to

be more prevalent in rehabilitation situations than for new construction.

The sixth was the background and skills of enforcement personnel; in

general many of the code enforcement agencies are staffed by building inspectors who have come out of the trades. They tend to be more prescriptiveoriented in terms of how they interpret codes and this was noted as a

problem which was more serious in rehabilitation than new construction.

This, then is just a brief background of where we are and the panelists

in this session will be giving their insights into the delivery system

and the real world problems of working with performance-oriented

rehabilitation documents.

117
II
Rehabilitation, Performance and the 'Real World' of the Code Official

by

Joseph Stein, P.E.

Construction Industry Consultant

Joseph Stein and Associates

Mr. Stein received a degree in Engineering

from the Columbia School of Engineering and

did graduate work in Structural Engineering

at the Brooklyn Polytechnic Institute.

Prior to establishing his own consulting firm

in 1978, Mr. Stein was First Vice President

of Tishman Construction and Research Company,

Inc. , where he was responsible for the firm's

midwestern Construction Management activities

.

Before joining Tishman he was Commissioner of

the New York City Department of Buildings—

the world's largest building regulatory agency—and in 1972 was instrumental in formulating an Energy Design Standard. Capitalizing

on his extensive background, he is currently

providing consulting services to government

agencies, owners, building product manufacturers, and other construction interests.

Mr. Stein is a Fellow of the American Society

of Civil Engineers (ASCE) , as well as numerous

other national organizations . He represents

ASCE on several professional committees and

was instrumental in organizing the Association

of Major City Building Officials

.

An advocate of better regulation and improvement of the regulatory delivery process, he

has participated in a number of national

panels on such subjects as codes and standards, energy, and metrication. Mr. Stein is

a registered Professional Engineer in the

States of Illinois , Pennsylvania and New Jersey.

VJhat I intend to present are some real world problems that I think you

have to face when you talk about a performance approach of any kind. Not

only in dealing with rehabilitation, but any time you mention the word

performance to a code official, I think he shudders. Not that he is less

intelligent than the rest of us; he recognizes that, really, given the

two options, performance makes much more sense than a prescriptive approach.

Why should we be told specifically what is required when rather we should

be told how a system should performi I think most of us here today are

committed to that approach.

119
II

The code official is the policeman who monitors the system—the impartial

(or supposed to be impartial) , third-party monitor—and he runs into

problems when he is forced to take other than a very low risk profile or

when he has to depend on subordinates to make the flexible decisions which

he will have to defend. Often he is limited by the capabilities of his

staff, although this is not always the case. But before I touch on those

restraints, I would like to discuss some issues that were raised before,

particularly something which sometimes goes unsaid or is said very

quietly—the exposure to graft and corruption.

Flexible requirements are conducive to bribery offers by the private

sector and coercion by corrupt officials. When I was a code official,

this was indeed a problem that I think we attacked forthright ly. We

recognized it was there and we did not try to sweep it under a carpet.

At that time, I thought that low salaries catalyzed whether or not an

inspector took a bribe. The situation in Chicago recently disproved that.

Some of the inspectors who took $25 and $50 handouts were making $26,000

and $28,000 a year. If someone is intrinsically honest, his salary will

not influence his taking a bribe

I

We also found that when an employee did take a bribe he was not going to

do something which would leave a monument for future exposure by violating

a technical code requirement. He, instead, took it for moving paper, expediting, or what have you.

Often when you try to attack that problem, you transfer the tendency or

the susceptibility of bribery to another sector. We actually ran into

bribery cases when we took some of the code responsibilities away from the

government and transferred them to the design professions. Are not improper decisions which are made based on a financial consideration called

bribes? The treat to an architect by a client of loss of future work to

influence a code decision is the same thing. This after-the-fact financial

consideration is as bad as the bribe given ahead of time. The more flexibility, the greater exposure to all types of illegal actions by both the

private and governmental sectors. It is there, it is a difficult problem

to handle and there is no question that the performance approach will

open many new doors and opportunities for the unscrupulous. Many in the

private sector feel that when they want an inspection or a decision, they

want it on their terms and feel that graft is money well spent. Let me

get off this subject, but this is as much a private sector problem as it is

a governmental one.

I intend raising some restraints, constraints, and other perceived problems ' with the process. It is like the senator who was in a rush and needed a

speech, directed his underpaid and harrassed speechwriter to produce a

speech on very short notice even though he had a very important family

affair to attend and he had to work all night on it. He vainly protested

and was given an ultimatvmi to produce. The senator grabbed the speech the

next morning without reading it and went to make his big presentation. He

went through all the world problems, the peace problem in the mid-east, the

shrinking dollar, the oil shortage, the environment and he said, "Ladies

and Gentlemen, I am not just going to throw these problems at you, I am

going to give you definitive solutions to every one of them." Flipping the

page he reads, "You '*!*', I quit, you can improvise from here."

120
I think I have some solutions to the problems. But, basically most code

officials, because of their conditioning, have adopted a very protective

no or low-risk philosophy in making their decisions. One of the reasons

is a very practical one; it is the scapegoat system, particularly where

the code official is a political appointee and not protected by a contract

or by civil service. There is also sensitivity to the action by the

media. There is never good press for the building department; it is

always the collapse, the bribery scandal, the unpopular decision that was

made. Positive PR is very rare I It is easier to say no or to study

something to death; that way you are going to limit that kind of exposure.

Also, I found that where the code official is a political appointee, and

something goes wrong, the code official is left there to hang by his own

thumbs. Nobody comes to his help; he has got to take the heat. If the

mayor is quoted, it is generally, "I don't know anything about these

technical matters." The code official generally hangs alone when there

is a problem. And that I speak from personal experience.

Another reason for code official sensitivity in taking risks is the first

grand jury hearing he appears before or the first legislative investigative

commission that grills him. Just go through one of those and you too would

adopt a low profile from there on in. You just say, I am not going to

stick my neck out again.

The exposure to personal liability is real. Even where there is not that

personal exposure in this litigation-happy society, the nuisance of a

law suit or a mandamus can deter a code official from making an innovative

decision or taking a risk that is properly motivated. In that general

area, I will give you a true personal experience where the code permitted

me, as Building Commissioner, to make discretionary rehab decisions. I

exercised them in the South Bronx for a non-profit minority church group

and nobody batted an eyelash. I did exactly the same interpretation for a

profit-motivated developer and I was "exposed" on television as being in

the back pocket of "real estate interests." Generally, you will find if

there is an issue, the media will not make a favorable interpretation of

anything that the code official does.

In terms of personal litigation, I think I still have a $2 million suit

personally pending against me because of an adaptive re-use of existing

building situation. A lot of the old lofts around 42nd Street in

New York City were converted to massage parlors and the City adopted a

campaign against them. Of course, I was sued for singling out one area

for enforcement and being accused of maintaining dual standards. The issue

of dual standards is one that lurks in the background of rehab as well.

I will give you a few reasons why the private sector does not like a

performance approach, although we all know why it is good. The private

entrepreneural sector traditionally makes large up front investments in

terms of purchasing property, retaining design teams, and so on. The private sector will feel very uncomfortable in not knowing, or being able to

predict what kind of decisions are going to come out of the other end in

121
a performance approach negotiation, unless there are some very clear

guidelines or case histories as to what types of decisions will be made

in interpreting the performance requirements. With a prescriptive

approach, he knows exactly what is going to be required and what he is

going to have to do and how much it is going to cost. From his point of

view he might even be happier with a 25-50% approach in terms of predictability of what is required, with less uncertainty as to the risk of

his up front investments.

Another area—the less affluent rehab sector—I think will have technical

difficulty in dealing with a performance approach, and I predict that we

are going to have some problems there in terms of requiring an architect's

input, which might not be required under the old 25-50% rule.

Aside from the constitutionality of the question of dual standards, I had

a protest once from a minority community group that protested some of our

rehab decisions in terms of reinforcing their "second class status" visa-vis, not getting full "new code" protection. I think you can appreciate

their reaction, "Why do we deserve less than new code safety protection?

This is another proof that we are second class citizens."

I can go on, but I only have four or five minutes left. To minimize the

uncertainty of future determinations by code officials, prefiling procedures, hearings, or conferences ought to be established. This will set

the philosophy of approach to trade-offs, to permit the developer (before

he goes marching down the road) to have a good idea as to what the code

officials will probably require in terms of performance solutions to the

problems. I think it is a good meeting ground, on an informal basis

before plans for the project even start, to have this type of interchange.

I personally do not think the old 25-50% rule ought to be abolished completely. I think it ought to be retained as an option on the part of

the applicant. I believe that for every performance requirement we ought

to have a prescriptive option, or to retain the old prescriptive requirement as an option if it is being replaced by a new performance statement.

We should require the design professional to evaluate the performance

requirement and to certify his recommendations to the code official. I

think the administrative portions of the code ought to permit the code

official, if he so chooses, to base his acceptance on the design professional's certification. I know what I am saying here and I know the

exposure to errors and omissions law suits, and everything else, but I

think this is what the design professional basically is being paid for

an57way. This certification will give the reluctant code official "the

hook to hang his hat on," and I think that ought to be an approach, too.

Except for malfeasance in office, the code official should be personally

indemnified and, in fact, the municipality should carry appropriate

surety or insurance to protect the code official against any personal exposure for any decisions he makes as a code official. I think an

employment contract should be considered for the appointed code official

or at least that his term of office should straddle two political

administrations so he will not be subject to political pressure in any

122
decision that he makes. This is another area where undue pressure sometimes is placed on the code official, inhibiting a proper determination.

And the last item I have is a possible approach to speed up or to avoid

a lengthy appeals process. I discussed the idea with the American

Arbitration Association to find out if it would be interesed in administering a rehab arbitration panel, either on a regional basis or on a

local basis, depending on the rehabilitation activity. I discussed the

idea of creating a rotating panel of say 100 or 200 experts who would sit,

on a weekly basis five at a time. The panel would be the back-up for the

reluctant code official who is afraid to stick his neck out to make a

performance determination. I think this is another possible approach in

determining whether or not the performance level of a building has been

changed within the same hazard group or whether or not alternate solutions

are truly acceptable trade-offs.

123

An Architect's View of Rehabilitation Regulation

by

Frederick A. Stahl

Principal

Perry, Dean, Stahl and Rogers

Architects

Mr. Stahl received a B.A. from Dartmouth

College in 1952 ^ graduated Harvard University Graduate School of Design in 1953,

and received a M. Arch, in 1955 from the

Massachusetts Institute of Technology.

Mr. Stahl is President of Perry, Dean,

Stahl and Rogers, where he is involved in

the design, renovation, restoration, and

conversion of and additions to various

buildings in the State of Massachusetts

.

These buildings include hospitals , university and school buildings, churches,

hotels, government buildings , and residential

buildings

.

Mr. Stahl has lectured at various schools

in Massachusetts and holds professional

registration in nine States and the District

of Columbia. He is a member of numerous

professional organizations and has received

many honors for his work, both in the

United States and England.

As an architect, I should like to pick up VThere Mr. Stein left off with

the question of liability. Our profession is in the process of re-thinking

questions of liability; it seeais that we are always looking around the room

to see who else is in there with us. I believe there is a good deal of

shared responsibility in our dealings with code officials, and I sympathize

and empathize with the dilemma of the official representing the public and

often not knowing quite how secure his position may be or how he will

defend his interpretations. The design professionals increasingly see

their responsibility and liability limited to the actual content of the

construction documents; the contractors may take a similar view of the

actual work as constructed. The position of the code official is frequently

less concrete, and often consists of a network of paths taken and interpretations made through the maze of overlapping requirements of the typical

code. As a result, in addition to professional competence, an effective

125
building official requires courage supported by adequate protection

against liability. I believe that the most sound basis will be found if

we first recognize the very real liability implicit in the actions of

each of the major actors in the building process. We have been extremely

fortunate in our practice in Boston in that we have almost invariably

dealt with building officials and builders who recognize these realities

and who are dedicated to getting the right decisions implemented within

the circumstances.

I should like to say a few more words about the situation in Massachusetts,

to clarify that Article 22 does not represent a new code and is not a

replacement for any portion of the administrative system in the Commonwealth.

It is a new article of the Massachusetts Code and I believe it is a significant achievement in that it recognizes a process that has been going on

more or less implicitly, and successfully, in many communities for a number

of years. However, with the creation of a new building code for the

Commonwealth, it was advisable to bring out from under the rug a number of

things that might have otherwise been left there. Much of what is embodied

in Article 22 acknowledges the way (and perhaps the only way) that wellintentioned and properly motivated, properly trained people can deal with

the issues as they come up in an existing building and provides a logical

formulation and a clear identification of the information required to substantiate a system of trade-offs.

The adoption of Article 22 should not be the end, but the beginning of a

series of steps which stem from it; a number of these steps fall within

the area of interest of this panel. We will need within the Commonwealth

and within the State Building Code Commission, and within the Boston Building Department, training for personnel in the use of this kind of methodology

now reduced to a more predictable and logical program. There is a constituency for this way of doing things which includes the code enforcement

people who will use it. Our initial salesmanship of this better or more

clear and more accessible way of dealing with decision-making, alternatives

and risk assessments must be directed first to the building officials

before we progress to the next stage in the field with consumers. Money and

time and training will be needed and we will have to find the incentives

and motivations for people to become interested in a more creative way and

in the greater flexibility that this system represents. Parallel tracks

on the research side must be initiated as Mr. Nelson referenced earlier,

and on the side of reform of the political process. We must make sure that

there is a congruency between the manner in which information is collected

and sorted and the framework for its use by persons in the field. A few

years ago when I served on a task group of the Building Technology Advisory

Committee on fire prevention, we discovered that fire statistics do not

tend to be collected in a way that is really revealing within the system

of building code enforcement. These problems become more and more apparent

if data is not organized in a way which relates directly to the categories

of risk established in Article 22, for example. A similar situation may

obtain in terms of definitions of occupancy and the actual physical

126
configurations of occupancy In so far as they are a factor of risk.

I believe we will find that the characteristics of risk differ in multifamily residential occupancies depending on the vertical division (townhouse)

vs. a horizontal division (apartment). A system of scoring and evaluation

such as that established by Article 22 of the Massachusetts Code requires

a congruent system of data collection in order to be effective; we cannot

assume that data in hand is sufficient or that its organization is

necessarily appropriate.

On the administrative side we must be in a position to demonstrate to people

in the everyday world that it does make sense to use judgment. I have

always found this completely convincing. In our office, we frequently take

the code apart, make multiple Xerox copies, and devote a wall to displaying

how a particular issue re-appears in multiple sections. We end up with the

code displayed in a way that is programmatic and with lines drawn connecting

issues in a kind of topological definition. We can then follow a given

issue through the code to our satisfaction, and select a scenario to present

to the code enforcement people saying, in effect, "Look, these are the

tracks that we found, and there are multiple tracks." As Mr. Nelson was

saying, there are many, many tracks through that document. Once we have

decided pretty much which tracks we ought to be on, we go to the code official

and ask for agreement on our identification of the tracks and relationships,

and backing for the tracks we have selected. We cannot go on all of them.

Nobody can. This is the kind of analytical program that many design professionals go through to be able to talk effectively in code terms about what

it is they are trying to do. If you visualize this situation in new construction, you may conceive how much more complex it is when confronted by

an existing structure. We try to understand what track it was on at the

point in time it became the way it is, and how we can adopt that track to a

greater or lesser degree and carry forward making use of systems generic to

that building.

I testified at the recent Proxmire Hearings, and have had some dealings with

the U. S. Department of Housing and Urban Development (HUD) off and on over

the years, although our office currently is not involved in work directly

under HUD programs. Most of the subsidized housing produced in Massachusetts

results from the activities of the Massachusetts Housing Finance Agency (MHFA)

,

which utilizes HUD subsidy funds but in a more programmatic and flexible

fashion which do not rely on the Minimxim Property Standards (MPS), Virtually

all design professionals would prefer to work with MHFA. I have seen the

MPS escalate the price of or the infeasibility of projects to either kill

them or to render them so absurd in design terms that they should never have

been undertaken. In our area, MHFA provides a system which is realistic

with respect to housing created within existing structures. I know that for

many years HUD has had rehabilitation guidelines. We have never seen them

and I do not know how many others have. At least in our geographical area,

under the Federal Housing Administration (FHA) , the MPS was the bible. It

provided a framework, complete to the last detail, which somehow had to be

imposed on every structure in order to become "housing," despite the

127
demonstrable livability of pre-existing units which did not comply.

Local code officials In any commvinlty that I know of are much more aware

of the reality. Where a local opportunity exists with a committed constituency of professionals, consumers and Investors, somehow a creative

resolution of code Issues Is found and found to be satisfactory. I am

afraid that unless someone Is prepared to confront the MPS Issue head-on,

that unless the document Is physically removed from use, a new set of

rehabilitation guidelines will never really be used. It Is my view that

none of the Issues around codes, and code reform to facilitate rehabilitation, are as Intractable as is the MPS when used in a categorical fashion.

The Advisory Committee for Building Technology of the National Bureau of

Standards had a subcommittee on building rehabilitation of which I was

chairman. The membership was broadly representative and highly qualified,

including Gordon Davidson (Vice President for Real Estate, Northwestern

Mutual Life), Leon Finney (President of the Woodlawn Organization, Chicago),

Dr. Sylvia Lane (University of California) and Jeremiah Walsh (New York).

We tried to address some of the bedrock issues, to provide outlines of

policy and priority and an agenda to the Bureau in what we saw as a very

rapidly accelerating activity of national significance.

We gave considerable importance to understanding the market, which is something that anybody in the private sector who wants to stay in business must

do. The market in rehabilitation has markedly different characteristics

from that of new construction. It is highly localized, much more sensitive

to life-style and community aspirations, and sensitive to building types.

Very likely along the East Coast there are twenty or thirty major market

segments which could be clearly identified. This process has been undertaken in Boston by building type and by neighborhood affinity. We believe

this is a useful way to view a building inventory; in effect we are saying

that the buildings may be there, and they may be interesting buildings, but

unless there is a market, xanless there is a constituency and a commitment

of financial and emotional capital, it may be interesting but not relevant.

Our motivation might be, "let's find out what people are trying to do

with which type of building, and how best to facilitate that endeavor,"

I believe we should facilitate rather than regulate, wherever possible.

The report of the subcommittee was very strong on this point, which is to

say that life-style issues, judgmental, cultural, bias kinds of Issues

ought to be deleted from codes. They are there for all kinds of reasons

going back well into the nineteenth century, those idiosyncratic regulations with which everyone is familiar.

Life safety issues must be clarified and documented; but what about everything else a tj^jical code carries with it? We need to divest ourselves of

the inheritance of a time when our governing bodies and elected officials

felt at ease making sure that people would only live in a certain way and

not in certain other ways. I am thinking of regulations of the type which

dictate when one may dine in the kitchen and when one may not; when a

128
child may share a bedroom with a parent, and when not; regulations which

treat light and ventilation requirements in offices vs. residences as

though we were dealing with different types of hxanan beings. I believe

it is time to increase our effectiveness to regulate the parameters that

have to do with life safety and to deregulate those which have to do with

life-style and cultural decisions.

We should not leave it there, however, recognizing that the starting point

for any building rehabilitation is someone who is making a commitment to

that building; someone who cares enough about it to live in it, to invest

in it or to take a risk with it. We should be responding to that, and a

large commitment of our time and effort in "code enforcement" should not

be enforcement at all, but assistance and guidance.

129

Administration of a Rehabilitation Code in a Major City

by

Creighton C. Lederer, Commissioner

Building and Safety Engineering Department

City of Detroit

Mr. Lederer earned a B.S. in Civil

Engineering from the University of

Michigan.

Mr. Lederer became the Commissioner and

Director, Building and Safety Engineering Department of the City of Detroit in

1971. Prior to that he served as the

Assistant Chief Engineer.

In addition to membership in the Building

Officials and Code Administrators International, Inc., American Railway and Bridge

Association, Society of Municipal Engineers,

American Public Works Association and the

National Academy of Code Administration,

Mr. Lederer is a Fellow of both the Engineering Society of Detroit and the American Society of Civil Engineers.

Mr. Lederer has held many offices and

received numerous awards in the engineering field and is a Registered Professional

Engineer in the State of Michigan.

Detroit's approach to building rehabilitation is somewhat like the old

fellow who goes to the doctor and the doctor says, "You need an operation;

[have you ever had one before?" and the old fellow says, "Yes." The doctor

says, "What for?" The fellow says, "For $500." The doctor says, "No, what

did you have?" The old fellow answered, "I had $300." "No, no, what was

the problem?" "The problem was that I was $200 short and that dam doctor

almost bankrupt me I"

1 That has been our approach to building rehabilitation in Detroit, it seems

to me; complying with code provisions that miss the point where the adaptive

re-use of buildings is concerned. Let me tell you something of our City.

131
I think our situation is similar to Boston. We have many of the same

problems except on a much broader scale. Detroit is the sixth largest

city in the United States. It has 500,000 dwellings units; 350,000 of

which are single-family dwellings. It is the largest single-family

dwelling home ownership in the United States. Detroit has 12,000 industrial and commercial and multi-family residential buildings that qualify

for rehabilitation of some sort. They are older buildings, ready to be

re-worked. Many of them are empty and need a stimulus for adaptive

re-use. When the opportunity came along to participate in this very

innovative experiment by the State of Massachusetts and the City of

Boston, I was pleased because I thought it could help Detroit. Also,

I was pleased to represent the Association of Major City Building Officials (AMCBO) ; the 30 largest major cities in the United States, and to

be responsible for keeping them informed of the progress. They are a

large constituency and are extremely interested in what is going on.

Detroit is the largest City in the United States that uses a model code.

We use the 1978 BOCA Code. The State also uses the same code but allows

the City special amendments to meet its needs. This has worked out relatively well. The model code has been good for uniformity; it has helped

eliminate discriminatory and restrictive practices in the use of building

codes. However, there are problems with this code. One of the problems

is with multi-family, industrial and commercial rehabilitation where the

25-50% rule is used. The City is obligated to interpret the code fairly

rigidly. It uses the replacement value which, in the City of Detroit,

is very often interpreted as the market value. Market value is tied

by law to the assessed value. Assessed values, particularly in depressed

areas, are reduced - and the problem is compounded. As the value of the

property goes down, the amount of rehabilitation that can be done without meeting new code requirements, becomes smaller. In addition, as

inflation raises the cost of construction, the cost of rehabilitation

rises and less and less work can be done before complete new construction

is required by code. This is the problem that Detroit has, that Boston

has, that Chicago has, that many other cities in the United States - especially the older ones - have in rehabilitating their buildings. For

the most part, we enforce new construction code provisions on rehabilitation

work.

I also want to review our experience in Detroit on some major rehabilitation programs that have worked. Detroit was probably the hardest hit by

the HUD problems in the early 1970' s. That large single-family home

inventory that I mentioned earlier resulted in HUD owning some 15,000

homes in the City of Detroit. Many unsophisticated people bought these

homes, were cheated, and abandoned them. They became HUD property. The

City worked out an arrangement with HUD and then with the Veterans' Administration to provide an inspection service that would lead to the

upgrading to prevent abandonment of those homes. This inspection service

covers the four basic systems of the house; structural, plumbing, electrical

and heating. A special furnace inspection was developed that was sensitive : and safe. It was an innovative program that demanded very strict

administrative control.

132

li
It was a program developed In response to a crisis situation. The City

underestimated the problem; HUD thought that it was selling 700 homes

a month when it was selling 2100 houses a month. Four inspectors were

sent out to each house. It did not take long to realize that a more

efficient approach had to be developed. One inspector was trained in

four disciplines and, I believe, that was the first time that that was

successfully done for existing buildings. The City managed—because of

the crisis situation—to overcome the union problems, to overcome training

problems, to overcome a host of other problems cind make the program work.

The program worked so well that the City Council last year adopted the

program in ordinance form. Any home that is now sold in the City of

Detroit, whether it is HUD-owned or privately-owned, has to have a City

inspection and be brought up to a minimum standard. One of the reasons

that that program is so successful is the administrative control that is

used. The Detroit rehabilitation program on single-family dwellings was

successful because we were able to establish community credibility using

a very tight administrative control. In fact, this is what Mr. Lewis was

saying, "the inspectors must be trained very carefully." The City of

Detroit's were trained in the electrical, heating, plumbing and structural

aspects of the building. We also had to make sure that they know where to

stop and to bring in the disciplined expert inspector. Detroit used a

"prescriptive" approach and restricted the inspectors to a check list.

The check list was published so that the community would know exactly what

the inspectors would be looking for.

I recognize that the Massachusetts rehabilitation project calls for a

completely new administrative approach. But this new approach must be

tried. Detroit has tried the prescriptive approach many times in the

rehabilitation of larger buildings; on buildings that have an adaptive

re-use. We fotind that the prescriptive approach did not work. I am convinced that a prescriptive approach on large buildings does not necessarily

trigger good administrative procedures. I am convinced that with good

administrative procedures, you can use innovative approaches as is trying

to be done here with the Massachusetts rehabilitation plan and that it can

be done in such a way to anticipate problems and manage them successfully.

We have done a lot of talking today about lack of uniformity. It is going

to be a problem. A concern that has been expressed to me by Joe Fitzgerald

in a letter — and I quote — (Joe Fitzgerald, by the way, is the Building

Commissioner of the City of Chicago and a very excellent building official)

,

"that one rehab job is continually going to be compared to the next; what

you give here is going to be demanded there and, as we well know, economics

is what counts. If it is cheaper, it is going to be very hard to hold the

line. Maybe we ought to formulize a systems concept."

The problem of uniformity is one of concern to most building officials of

the larger cities. They are concerned that they will not be able to maintain iiniformity. I am afraid that it is a problem we are going to have to

learn to live with, I think we are going to have this problem regardless

of what is done. We talked about training. It is important. It is important to understand that in starting a program like this, where the parameters

are broad, extra attention must be given to training. But, it seems like

133
I

the problem of uniformity is one of concern to most building officials of

the larger cities. They are concerned that they will not be able to

maintain uniformity. I am afraid that it is a problem we are going to

have to learn to live with. I think we are going to have this problem

regardless of what is done. We talked about training. It is important.

It is important to understand that in starting a program like this, where

the parameters are broad, extra attention must be given to training. But

it seems like all the pieces may be coming together. The National Academy

of Code Administration is dedicated to a program for developing better

trained, better qualified building officials and inspectors.

One of the administrative problems that we are going to have is more cases

going to a Board of Rules. Some building officials are loathe to take

responsibility or use the discretion granted to them under the Massachusetts!

rehabilitation approach. I believe that this will rectify itself in time.

In Detroit, an administrative committee procedure is used to act quickly

on matters of interpretation. A select group makes recommendations to the

Director and he may refer the matter to the Board of Rules. Administrative

committee decisions are made within one week. Those problems requiring

code waivers or deviations are transmitted to our Board of Rules.

Some codes do not allow code waivers. The BOCA Code does, and the City

utilizes it. A Board of Rules usually consists of citizens, architects,

engineers and, in Detroit's case, the heads of four major departments

(Health, Fire, Building and Lighting). In my own mind. Board of Rules

decisions for rehabilitation will become less frequent once there is an

understanding of how the new rehabilitation code process works. More importance will be placed on pre-permit conferences. We all use. these conferences to some degree but they should be an intrinsic part of the

rehabilitation process. Then monitoring is essential, both by the building

officials and the engineer or architect, to make sure the discretionary

rules are being followed.

I have tried to review some administrative processes that will help make

a Massachusetts rehabilitation code successful. Many of these concerns

have been voiced by the building officials from large municipalities. They

recognize, however, that this approach has a chance for success where

others have failed. The large urban areas of the United States are deeply

troubled with physical, social and economic problems. Some are coming

back. In my opinion, the Massachusetts rehabilitation code represents a

first effort to take an innovative approach to encourage the rehabilitation

and adaptive re-use of our major buildings. To that point - in Houston,

last week, the Association of Major City Building Officials' Executive

Committee reviewed and approved the concept of the Massachusetts rehabilitation code as it has been outlined to you today. We have, I hope,

pointed the way for our cities to regain health and momentum in the future.

134
PANEL DISCUSSION

QUESTION ; John McMahon, Institute of the Ironworking Industry

I would pose a set of circumstances to Mr. Stein for his

comment. Not the consciencious rehabilitation of an existing building with the design team, but rather the partial,

but continual, renovation and rehabilitation of commercial

space that occurs every time a lease is up. The building

manager says to the new tenant, "I have a brother-in-law

who does this nights and weekends," and proceeds to work at

nights and weekends on puncturing the integrity of the slab

and runs a bunch of holes up through it into partitions and

nobody is the wiser. It is beyond the code, and within 10

years the whole building is without code protection and

nobody is the wiser. How do you get a handle on that - from

the Tishman point-of-view and from the city point-of-view?

What do you do with nights and weekends when your people are

out with their families like they should be and the city is

being remodeled outside the code?

RESPONSE ; Joseph Stein, Joseph Stein and Associates

You forgot the result and collapse of the building because a

bearing wall was knocked out and some people got killed.

Well, I will tell you, that is one aspect of building regulation that some of the codes try to address in requiring

periodic inspections of buildings.

In a city like New York, which has close to 900,000 structures —not dwelling units, but structures—it is nearly impossible

to do that. I think it is possible in small communities with

the inspectorial group to have periodic inspections of the

status of the existing building and this is done I know. The

City of Chicago does it; they do this rather efficiently and

in areas where this leads to other exposure, of course. Many

times picky little things are found, where they really do not

affect the safety or performance of the building and they

merely use this device in that other area I was talking about.

Another device is also used to require periodic inspections,

making it the responsibility of the building owner to have

such inspections performed on his building by a certified

third-party, this could be architect, engineer or some other

inspectorial service. We did this in some of the mechanical

areas in New York where we just did not have the staff to do

it, with elevators for example. Others can be deputized to

do this

.

135
When a building Is going up, you cannot stand In back of

every workman to make sure he Is doing his job properly,

you can only monitor. And what you are saying, I know

happens. The only way to really keep a handle on that Is

to periodically Inspect the building. Other than that, I

really do not have an answer to the problem. It does go on

and many people do It unknowing that there Is a regulation

or a requirement, or that they are not allowed to be doing

what they are doing. What Is your suggestion, do you have

any suggestions?

COMMENT ; John McMahon, Institute of the Ironworklng Industry

No, I was wondering how you do get a handle on It.

COMMENT : Joseph Stein, Joseph Stein and Associates

In most codes there Is a requirement that buildings be

periodically Inspected. In fact, the fire department in

many cases, has the responsibility to review the performance

of the building after it is erected in terms of fire safety.

It is its ongoing responsibility to see that the fire code

is being followed.

COMMENT ; John McMahon, Institute of the Ironworklng Industry

I am very serious about this. When the fire department comes

back in for its periodic inspection, if it does, or if anyone

does, who is to know where the Interior partitions were previously laid out, unless you look into the plans and start

looking for holes? I mean it really is an impossible thing

to keep up with.
APPENDIX A

ATTENDEES

NATIONAL CONFERENCE ON REGUUflORY ASPECTS OF BUILDING REHABILITATION

National Bureau of Standards

October 30, 1978

Charles W. Almand

D. S. Gypsum

Joseph J. Anselmo

Urban-Six Associates, Inc.

Kenneth M. Aughenbaugh, Jr.

Neighborhood Housing Services, Inc.

James R. Bell

National Fire Protection Association

Sandra A. Berry

National Bureau of Standards

David E. Brackett

Gypsum Association

George H. Brattln

Massachusetts State Building Code Commission

Ben Brungraber

B & B Engineered Timber

Roderick Buchan

National Forest Products Association

Jeffrey W. Burton

University of Illinois

Thomas Careaterra

The Preservation Technology Group, LTD.

T. H. "Nick" Carter, Former Executive Director

International Conference of Building Officials

Elinor J. Champion

Arthur G. Chrlstensen, U. S. Department

of Housing and Urban Development

Patrick W. Cooke

National Bureau of Standards

Calvin L. Cooksey

Donald A. Crews

Delaware Energy Office

Sarah K. Crlm

Housing and Urban Development Reporter

Philip E. Cronible, Jr.

U. S. Fire Administration

Bernard A. Cummlngs, National Association

of Housing and Redevelopment Officials

Joseph Del Grosso, U. S. Department

of Housing and Urban Development

Leonard G. DeStout

Cast Iron Soil Pipe Institute

H. Brian Dickens

National Research Council of Canada

Charles J. Dinezio, Executive Director

Massachusetts State Building Code Commission

Lee S. Disharoon

City of Salisbury, Maryland

Zack Domlke

Neighborhood Housing Services, Inc.

James Dowling

American Institute of Architects

William Drlpps, National Conference of

State on Building Codes and Standards

Arthur Duncan

American Institute of Architects

Kenneth S. Eisenberg

The Preservation Technology Group, LTD.

Robert M. Elsenhard

National Bureau of Standards

Thomas Falson

National Bureau of Standards

Pastor Farinas

Montgomery County, Maryland

Lisa M. Farrell

Consultant

John J. Fiedler

Montgomery County, Maryland

William E. Fitch

Owens Coming Fiberglas

Paul Folkins

City of Boston Building Department

Alan S. Forman

Maryland Association of Realtors

137
-2-

Irwin Fruchtman

New York City Connnlssloner of Buildings

Barbara Ann Gelsman

City of St. Louis » Missouri

Mike Gerecht

Housing Affairs Letter

Harold J. Gorman

City of New Orleans, Louisiana

Richard A. Gray, U. S. Department

of Houiing and Urban Development

James G. Gross

National Bureau of Standards

John R. Groves, Jr.

State of Kentucky

Hurbert E. Guest

City of Cincinnati, Ohio

Grant Halvorsen, State University of

New York at Buffalo

Steven A. Hamburger

George Washington University

Gary E. Harrison

City of Akron, Ohio

Jahn Has lam

State of Florida

Robert C. Hllprecht

State of Michigan

Victon Jones

City of Cincinnati, Ohio

Chris Kane

George Washington University

Robert J. Kapsch, U. S. Department

of Housing and Urban Development

John Kariotls

Kariotis, Kesler, and Allys

Russell V. Keune

National Trust for Historic Preservation

John W. Kinney

State of North Carollrfa

David Krebs

Howard County, Maryland

Jerrlly R. Kress

The Preservation Technology Group, LTD.

Richard Kuchnlckl

National Association of Home Builders

Creighton Lederer

City of Detroit, Michigan

Robert H. Lee

New Jersey Housing Finance Agency

Frank Lerchen

National Bureau of Standards

Walter E. Lewis

University of Illinois

Nicholas R. Loope, United Brotherhood

of Carpenters and Joiners of America

B. L. Lowery

City of Atlanta, Georgia

Donald T. MacRae

State of Indiana

Howard Markman

U. S. Fire Administration

Ileana Martinez

National Bureau of Standards

Murvan M. Majcwell

City of New Orleans, Louisiana

John McClaughry

National Commission on Neighborhoods

Maureen McGraw

Texas A & M University

John McMahon

Institute of the Ironworklng Industry

Gary L. Miller

Montgomery County, Maryland

Paul J. Moriar'lty

Massachusetts State Building Code Commission

Harold E. Nelson

National Bureau of Standards

Wayne G. Norrls

Montgomery County, Maryland

Edward I. Osborne

Thomas & Betts Company

138
-3-

Donald Plnkerton, National Conference of

States on Building Codes and Standards

James H. Flelert

National Bureau of Standards

William Plouffe

Charleswater Associates, Inc.

'

Anita Rechler, U. S. Department

of Housing and Urban Development

Elliott Relff

State of New Jersey

Jane Rlppeteau

Engineering News Record

Courtney Robinson

State on Indiana

Nathaniel H. Rogg

Industry Consultant

Reva G. Roman

Construction Management, GSA (retired)

William Rowe

Consumer Product Safety Commission

Phyllis Ann Santry

Trl-State Regional Commission

Kenneth M. Schoonover, Building Officials

and Code Administrators International, Inc.

Robert Seely

Montgomery County, Maryland

Bennett Selekof

State of New York

James F. Shlvar

U. S. Department of Energy

James A. Smith

City of Atlanta, Georgia

Frederick A. Stahl

Perry, Dean, Stahl and Rogers

Joseph Stein

Joseph Stein and Associates

William J. Stlnson

City of Omaha, Nebraska

Walt Tomslc

State of Colorado

Melvln Tull

Montgomery County, Maryland

Christopher G. Tyson

American Iron and Steel Institute

Durwln Ursery

Urban Investment and Development Company

Any Van Doren

National Association of Home Builders

Harry Wennlng

Solar Structures, Inc.

John Wennlng

State of Wisconsin

William A. Webb

Rolf Jensen and Associates

Robert Wlble, National Conference of

States on Building Codes and Standards

R. Thomas Wlllson

American Iron and Steel Institute

James R. Wright

National Bureau of Standards

139

Massachusetts State Building Code

RECOMMENDED PROVISIONS

ARTICLE 22

REFERENCE STANDARDS

RS 22-1, RS 22-2, RS 22-3, RS 22-4

Repair, Alteration, Additions

eUld

Change of Use of Existing Buildings

October 23, 1978

141

Massachusetts State Building Code

RECOMMENDED PROVISIONS

ARTICLE 22

REPAIRS, ALTERATIONS, ADDITIONS

and CHANGE OF USE

OF EXISTING BUILDINGS

October 23, 1978

INDEX TO ARTICLE 22

REPAIRS, ALTERATIONS, ADDITIONS

and CHANGE OF USE

Pa^e

2200.0 SCOPE 1

2200.1 GENERAL 1

2201.0 DEFINITIONS 1

2202.0 APPLICATION 2

2202.1 GENERAL 2

2202.2 REPAIR OR ALTERATION 2

2202.3 ADDITIONS TO EXISTING BUILDINGS 2

2202.4 CHANGE IN EXISTING USE 2

2202.4.1 CONTINUATION OF EXISTING USE 3

2202.4.2 CHANGE IN USE 3

2202.4.3 PART CHANGE IN USE 3

2202.5 HISTORIC BUILDINGS 4

2202.6 REFERENCE STANDARDS 4

2203.0 REQUIREMENTS 4

2203.1 BUILDINGS EXCEEDING CODE REQUIREMENTS

FOR NEW CONSTRUCTION 4

2203.2 BUILDINGS NOT MEETING CODE REQUIREMENTS

FOR NEW CONSTRUCTION 4

2203.3 COMPLIANCE ALTERNATIVES 5

2203.4 ADDITIONS 5

2203.5 INCREASE IN FLOOR LOAD 6

2203.6 HAZARDOUS CONDITIONS .... 6

2203.6.1 STRUCTURAL

•

6

2203.6.2 NUMBER OF EXITS 6

2203.6.3 CAPACITY OF EXITS 7

2203.7 NO CHANGE IN USE 7

2203.7.1 MINOR ALTERATIONS AND REPAIRS 7

2203.7.2 NEW SYSTEMS 7

2203.7.3 INCREASE IN OCCUPANCY LOAD 7

145
Paae

2203.7.4 INCREASE IN NUMBER OF DWELLING UNITS 7

2203.7.5 PLACES OF ASSEMBLY 8

2203.8 CHANGE IN USE GROUP 8

2203.8.1 EQUAL OR LESSER HAZARD 8

2203.8.1.1 NEW SYSTEMS 9

2203.8.1.2 EXIT SIGNS AND LIGHTS 9

2203.8.1.3 MEANS OF EGRESS LIGHTING 9

2203.8.1.4 PIRE^ ALARM SYSTEMS 9

2203.8.1.5 ENCLOSURE OF STAIRWAYS 9

2203.8.1.6 PLACES OF ASSEMBLY 9

2203.8.2 GREATER HAZARD 9

2003.8.2.1 INCREASE IN ONE HAZARD INDEX NUMBER 9

2003.8.2.2 INCREASE IN TWO OR MORE HAZARD INDEX NUMBERS . 11

TABLE 2203.8 HAZARD INDEX 12

146 Art. 22
PROPOSED CODE PROVISIONS FOR EXISTING BUILDINGS

ARTICLE 22

REPAIRS, ALTERATIONS, ADDITIONS

and CHANGE OF USE

SECTION 2200.0 SCOPE

2200.1 GENERAL: The intent of these provisions is to provide for

the public safety, health and general welfare by permitting

repair or alteration of, additions to, and change of use of,

existing buildings and structures or parts thereof without

requiring the existing building or structure to con^ly with

all of the requirements of this code for new construction

except where otherwise specified in this article.

SECTION 2201.0 DEFINITIONS

Definitions shall be construed as being the same as defined

in Article 2 except as follows:

Existing Building or Structure : Any completed building or

structure.

Occupancy Load: The maximum number of individuals for which

the building and the exitway facilities have been designed

.

Occupancy : The purpose for which a building, or part thereof,

is used or intended to be used.

^ Art. 22
Use Group ; The classification of a building or structure

based on the purpose for which it is used as set forth

in Sections 203 through 212.

SECTION 2202.0 APPLICATION

GENERAL: Where there are no specific provisions in this

article applying to the repair, alteration of, additions

to, and changes of use of any existing building or structure

or part thereof, then such building or part thereof shall be

made to comply with the pertinent provisions of this code

for new buildings or structures. The provisions of this

article shall apply to existing buildings and structures

which have been occupied and/or used for a period of at

least one year.

REPAIR OR ALTERATION: The repair or alteration of existing

buildings and structTires shall comply with the requirements

of this article, except for ordinary repairs as provided for

in Section 102.

ADDITIONS TO EXISTING BUILDINGS: Additions to existing

buildings and structures shall comply with the requirements

of Section 2203.4.

CHANGE IN EXISTING USE:

2 Art. 22
2202.4.1 CONTINUATION OF EXISTING USE: The legal use and occupancy of

any building or structure may be continued without chamge, except

as may be specifically covered in Sections 405.1 and 405.2 of

this code or as may be deemed necesseur/ by the building official

for the general safety and welffure of the occupants and the

public.

2202.4.2 CHANGE IN USE: No change shall be made in the use group of

any building which would place the building in a different

use group unless such building is made to comply with the

requirements of this article.

2202.4.3 PART CHANGE IN USE: If a portion of the building is changed

to a new use group, and that portion is separated from the

remainder of the building with the required vertical and

horizontal fire separation assemblies complying with the

fire grading in Taisle 902, or with approved con^liance alternatives, then the portion changed shall be made to conform

to the requirements of this curticle.

If a portion of the building is changed to a new use

group, and that portion is not separated from the r^nainder

of the building with the required vertical and horizontal

fire separation assemblies complying with the fire grading

in Table 902 or with approved compliance alternatives, then

the provisions of this article applying to each use shall

apply to the entire building, and if there are conflicting

, Art. 22
provisions the requirements securing the greater public safety

shall apply.

2202.5 HISTORIC BUILDINGS: Historic buildings Shall meet the applicable

provisions of Article 4 of this code.

2202.6 REFERENCE STANDARDS: The building official may use the RS 22

series of reference standards when determining coii^>liance with

this article.

SECTION 2203.0 REQUIREMENTS

2203.1 BUILDINGS EXCEEDING CODE REQUIREMENTS FOR NEW CONSTRUCTION:

Existing buildings and structures which, in part or as a

whole, exceed the requirements of this code may, in the

course of compliance with this article, reduce or remove

in part or total, featiires not required by this code for

new construction, provided, however, that such features

were not a condition of prior approval.

2203.2 BUILDINGS NOT MEETING CODE REQUIREMENTS FOR NEW CONSTRUCTION:

Pro\^ded their present degree of compliance to the code is

not reduced, existing buildings and structures v^ch, in part

or as a whole, do not meet the requirements of this code for

new construction may be altered or repaired without further

compliance to the code under the provisions of this article.

4

Art. 22
2203.3 COMPLIANCE ALTERNATIVES: Where con5)liance with the provisions of this code for new construction, required by this

article, is impractical because of construction difficulties, acceptable compliance alternatives may be used.

Reference Standard RS 22-2 contains some acceptable compliance alternatives. The building official may accept

compliance alternatives other than those listed in RS 22-2.

2203.4 ADDITIONS: Additions to an existing building shall comply

with all code requirements for new construction. The combined height and area of the existing building and new

addition shall not exceed that permitted by this code for

new construction. Where a fire wall complying with Section

907.0 is provided, the addition may be considered as a

separate building. However, the existing building shall

con^ly with Sections 2203.1 and 2203.2.

The addition shall not impose loads either vertical or

horizontal which would cause the existing building to be

subjected to stresses exceeding those permitted by this code

for new construction.

5 Art. 22
2203.5 INCREASE IM FLOOR LOAD: Any increase in floor loading shall

be investigated to determine the adequacy of the existing

floor system to support the increased loads. If the existing

floor system is found to be inadequate it shall be modified

to support the increased loads or the proposed allowable

floor loading shall be reduced and posted.

2203.6 HAZARDOUS CONDITIONS: The conditions or defects described

below shall be deemed to be hazardous and shall be corrected.

Nothing in this section shall be construed to limit the

authority of the building official under Section 123.0.

2203.6.1 STRUCTURAL: Any building or structvire or portion thereof

which is in imminent d2uiger of collapse because of, but not

limited to:

(1) dilapidation, deterioration, or decay;

(2) faulty design and/or construction;

(3) the removal, movement or insteUsility of any portion

of the ground necessary for the purpose of supporting

such building;

(4) the deterioration, decay or inadequacy of its foundation.

2203.6.2 NUMBER OF EXITS: Less than two (2) approved independent

exitways serving every story, except in one- and two-family

dwellings and as modified in Sections 417.0, 418.0 and 609.3.

6 Art. 22
2203.6.3 CAPACITY OF EXITS: Any required door, aisle, passageway, stairway or other required means of eqress which is not of sufficient

width to comply with Section 608, or is not so arranged as to

provide safe and adeqiiate means of egress.

2203.7 NO CHANGE IN USE

2203.7.1 MINOR ALTERATIONS AND REPAIRS: Alterations or repairs which

do not adversely affect the performance of the building may be

made with the same or like materials.

2203.7.2 NEW SYSTEMS: When the proposed alteration does not involve a

change in use group then no further compliance with the

requirements of the code for new construction is required

except that any new building systems shall conform to the

code for new construction to the fullest extent physically

practical in accordance with Section 2203.3 of this eurticle.

2203.7.3 INCREASE IN OCCUPANCY LOAD: If an increase of greater than

15% in the occxipancy load is involved, the building shall

comply with this code for new construction with regard to

egress requirements. Existing exitway facilities may be

used in contributing to the total calculated egress requirements.

2203.7.4 INCREASE IN NUMBER OF DWELLING UNITS: If the nun±>er of

dwelling units in buildings of use group R (residential) is

7 Art. 22
increased, the building aheO^l comply with Sections 2203.8.1.1

through 2203.8.1.5 inclusive.

V

2203.7.5 PLACES OF ASSEMBLY: Nothing herein contained shall prohibit

the alteration of a building heretofore occupied as a place

of public assembly for such continued use provided the seats,

aisles, passageways^ balconies, stages, j^purtenauit rooms and

all special permanent equipment comply with the requirements

of Sections 417.0 amd 418.0.

2203.8 CHANGE IN USE GKOUP: Any change in use to use group I (Institutional) shall coolly with the requirements of this code for

new construction. For all other changes in use, the building

official shall first determine whether the alteration results

in a lesser, equal, or greater hazaurd in accordance with

Table 2203.8. Change in use group shall be evaluated relative

to the last known legal occupancy of the building.

2203.8.1 EQUAL OR LESSER HAZARD: When the proposed use is of equal

or lesser hazard no fvirther compliance with the code for new

construction is required except as specified herein. Alterations or repairs to an existing building or structiire which

do not adversely affect the performance of the building may

be meuie with like materials. Any proposed change to the

existing building or change in type of contents of existing

building shall not increase the fire hazard to adjacent

o Art. 22
buildings or structures. If the fire hazard to adjacent

buildings or structures is increased, then the requirements

of Table 214 for exterior walls shall apply.

2203.8.1.1 NEW SYSTEMS: Any new building system shall conform to this

code for new construction to the fullest extent practical

in accordance with Section 2203.3 of this article.

2203.8.1.2 EXIT SIGNS AND LIGHTS: Exit signs and lights shall be provided

in accordance with Section 623.0.

2203.8.1.3 MEANS OF EGRESS LIGHTING: Means of egress lighting shall be

provided in accordance with Section 624.0.

2203.8.1.4 FIRE ALARM SYSTEMS: Fire alaxm systems shall be provided in

accordance with Sections 1216.0 and 1217.0.

2203.8.1.5 ENCLOSURE OF STAIRWAYS: Open stairways shall be enclosed

except as otherwise permitted by Article 6. For the purpose

of this section only, there shall be no minimum fire resistance

rating for the enclosure. All doors in the enclosure shall be

self-closing.

2203.8.1.6 PLACES OF ASSEMBLY: All buildings of use group A (assembly)

shall comply with Sections 417.0 and 418.0.

2203.8.2 GREATER HAZARD

2203.8.2.1 INCREASE IN ONE HAZARD INDEX NUMBER: When the proposed change

in use results in a use group one hazard index number higher

Q Art. 22
than its present use group as defined Table 2203.8 the entire

building must meet the requir^ents of the code for new construction with the following exceptions:

a. No fxirther con^liance is required with Sections 213.0

and TaQale 902 except that floors providing horizontal

separation in buildings of types 3 and 4 construction

equipped with a fire suppression system shall have a

fire resistance rating of not less than one (1) hour.

b. No further compliance is required with Section 302.2.

c. NO further compliance is required with Sections 305.2

amd 305.3, e.g. a change in use is allowed in an

existing structure even if it exceeds the area and

height limits of Table 305.

d. No further coopliemce is required with Section 315.1.

e. Con^liance is required with Section 616.0 except that

existing exitway stairways may be used as part of the

required egress for the new use, provided that the

width is of sufficient capacity for the occupancy

load, they are structurally sound, and that the

enclosures in buildings to types 3 and 4 construction

shall have a fire resistance rating of not less than

one (1) hour. Enclosures in buildings of types 1 and 2

10 Art. 22
construction shall have a fire resistance rating of not

less than two (2) hours. Where stair exitway doors are

doors to an apartment or office they need not swing onto

the landing.

f. Earthquake resistance and liquefaction. No further

compliance to Sections 718.0 and 723.0 is required.

Structural alterations may be made to existing buildings and other structures, but the resistance to

lateral forces shall not be less than that before

such alterations were made, unless the building or

structxire as altered meets the requirements of this

code for earthquake loads.

g. No further conpliance is required with Section 815.0.

h. " No further conpliance is required with Sections 868.0

and 907.0. The height above the roof of existing fire,

party and exterior walls need not comply with these

sections.

2203.8.2.2 INCREASE OF TWO OR MORE HAZARD INDEX NUMBERS: When the proposed change in use results in a use group two or more hazard

index numbers higher than its present use group as defined in

Table 2203.8, the entire building must meet the requirements

of this code for new construction.

11 Art. 22
TABLE 2203.8

UAZAiU) INDEX

Scale: 1-8 (1 is lowest; 8 is highest hazard)

Use Group* Description Index No,

A-l-A Theatre with Stage 6

A-l-B Theatre w/o Stage 5

A- 2 Night Club 7

A- 3 Restaurant 5

Lecture Halls, Rec.

Centers , Museums

,

Libraries, Similar

Assembly Buildings 4

A-4 Churches & Schools 4

B Business 2

F Factory & Industrial 3

H High Hazard 8

I-l Institutional Restrained 5

1-2 Institutional Incapacitated 4

M Mercantile 3

R-1 Hotels, Motels 2

R-2 Multi-Family 2

R-3 1 & 2 Family 2

S-1 Storage, moderate hazard 3

S-2 Storage, low hazard 1

* See Sections 203 through 212 of the Massachusetts State Building

Code and Reference Standard RS22-3.

12 Art.
Massachusetts State Building Code

REFERENCE STANDARD

RS22-1

GUIDELINES FOR APPLICATION OF ARTICLE 22

October 23, 1978

159

REFERENCE STAFfDARD RS22-1

GUIDELINES FOR APPLICATION OF ARTICLE 22

Table of Contents page

I. Purpose 1

II. Scope 1

III. Statement of Concept 2

IV. Implementation 2

A. Evaluation of Existing Building 2

1. Available Documentation of Existing Building 3

2. Field Surveys 4

3. Testing 4

a. Field Tests 5

1. Non-destructive testing 5

2. Destructive testing 6

b. Laboratory Analysis 6

B. Evaluation of Change in Performance Level 7

1. Data on Archaic Systems 7

2. Compliance Alternatives 7

3. Analysis Methods 8

4. Test Methods 8

5. Professional Judgment 8

161 RS22- 1

REFEREIJCE STANDARD RS22-1

GUIDELINES FOR APPLICATION OF ARTICLE 22

X. Purpose

The purpose of this guideline is to provide guidance to users of the

Massachusetts State Building Code to techniques of acceptable practice

which can be used to assess the acceptability of various methods of meeting

the intent of the code provisions of Article 22 on a case-by-case basis.

The purpose of the code provisions in Article 22 and this guideline is to

allow alterations r repairs and additions to existing buildings without

requiring the entire building to be brought up to new construction requirement

but still providing for the public health* safety and general welfare. The

provisions of Article 22 and this guideline recognize that the provisions af

the Massachusetts State Building Code for new construction reflect the latest

improvements in materials » construction techniques* standards of living and

safety and therefore may preclude the repair* alteration or additions to

existing buildings that have demonstrated their usefulness and safety.

II. Scope

This guideline and the RS22 series of Reference Standards are intended

to demonstrate techniques of analysis and compliance with Article 22 of the

Massachusetts State Building Code in the repair* alteration* and additions .

to existing buildings including change in use.

1 RS 22-1
III. Statement of Concept

Conceptually, it is the Intent to allow repairs, alterations, additions to and change in use of existing buildings without meeting all new

construction requirements under the following general conditions:

1) all hazardous conditions oust be corrected;

2) the existing building becomes the minimum

performance standard;

3) the degree of compliance of the building after

changes must not be below that existing before the changes

except nothing in this section will require compliance with

requirements more stringent than that required for new construction.

IV. Implementation

In^lementation of the above concept requires that a framework be

established for:

• evaluating the condition of the building;

• determining the potential for modification;

• establishing the acceptability of proposed changes.

A. Evaluation of Existing Building

Evaluation of existing conditions in a structure is required to:

• determine the existence of euiy hazardous conditions which

must be corrected;

• provide a basis for evaluating the impact of the proposed changes

on the performance of the buildin?.

2 RS22-1
The following list of tools can be used for determining the condition of

the structure. However, the list may not be complete and the use of others

should not be precluded.

1. AvailaOale Documentation of Existing Building

A prime source of design information of an existing building are

the architectural and engineering drawings And specifications used in

the construction of the building. Although the passing of time often

obscures the identities of depositaries of such documents, the following are likely prospects in attempting to locate such information:

a. If the building is currently in use, an individual or

office responsible for its management may have retained drawings

and specifications to facilitate maintenance. A building manager,

resident engineer, superintendent, custodian, stationary engineer

or plant engineer may be the most direct contact at the building

site.

b. Other potential sources (especially if the building is

not in use) incliide the original designer-architect or engineer.

C. The building department which issued the permit for

construction may have documentation.

d. Documentation may have been retained by the general contractor or numerous subcontractors. This presents the possibilities of the mason, carpenter, plumber, electrician, HVAC

installer, steel erector, etc., as well as manufacturers of

component parts.

, RS 22-1
In the case of large corporations or government agencies,

a separate contracting officer may have developed a technical

file on the erection of a building.

f. In some cases, individual consultemts are contracted to

serve as "clerk-of-the-works" and pursue the inspection of a

building project from start to finish with a file likely.

g. Historical or archaeological societies may have considered a building to be important enough to develop a file of

documentation

.

2. Field Surveys

Having drawn upon available documentation to help evaluate a

building's condition, such documentation may be augmented by on-site

data acquired through field survey. The most obvious approach is to

make use of detailed visual exaunination to confirm and/or alter any

previously available infoznation pertaining to the building.

3. Testing

Testing is a tool that may be used in evaluating the condition

of a building or structure or parts thereof when other methods of

evaluation will not suffice. Testing may be initiated voluntarily

on the part of the permit applicant or may be required by the

building official in the absence of approved rules as indicated in

Section 800.6 of the code. This section points out that "...

the building official shall make or cause to be made the necessary

4

RS 22-1
tests and investigations, or he shall accept duly authenticated

reports from recognized authoritative sources." The costs of all

such tests are to be borne by the permit applicant and should

therefore be required by the building official only when other

giethods of evaluation prove inadequate or insufficient . Such

testing should be conducted by an approved testing agency

under the supervision of a registered architect or engineer. The

report of the tests shall be submitted to the building official

and shall include the details of test procedures, references to

any accepted test standards used, the results of the tests and any

conclusions drawn from the test results.

a. Field Tests . Both non-destructive and destructive test

procedures can be applied to evaluate the condition of a building.

1. Non-destructive testing - This includes techniques

where the structural integrity of the building is not

affected, such as:

• analyzing various portions of the building to

determine dimensions, types and condition of

materials, etc.

• portable apparatus for impact testing

• load application short of failure to determine

capacity of materials and components

RS 22
• magnetic methods for detecting flaws in ferrous

metals

• proximity magnetometers (locating rebars in

concrete, concealed ferrous fasteners, etc.)

• electronic means for measuring the sonic modulus

of elasticity of concrete and masonry in assessing

its soundness

• ultrasonic transmission or reflective methods in

detecting flaws in various materials

• x-ray or infrared-ray photographic techniques can

be used to evaluate portions of elements whose

integrity is questioneible.

2. Destructive testing

• sample of the building could be removed and tested

(e.g., concrete core)

• components of the building could be reconstructed

and tested in the laboratory.

b. Laboratory Analysis . In some cases tests can be performed in the laboratory including:

1. Chemical or metallurgical tests.

2. Optical or electronic microscopic examination can

help identify and evaluate the soundness of materials where

decay or other molecular degradation is involved.

6 RS22-1
3. Convsntional laboratory tests for determining

physical properties (strength, ductility, absorption,

solubility, permeability, strength, stiffness, etc.).

4. Testing of a scale model of the building (computer

model, wind tunnel model, etc.).

B. Evaluation of Change in Performance Level

It is necessary to determine if the level of performance of the building after alteration is below that v^ich existed before the change. The

hazard level could be increased for certain attributes (e.g., fire safety)

while decreasing for other attributes (e.g., floor loads) for a given alteration. The evaluation of the change in hazard levels of each attribute can

be accomplished using various tools singly or in combination as described

below.

1. Data on Archaic Systems . Performance data on architectural

eund structural systems being encountered in existing buildings in

the Commonwealth are tabulated in RS 22-4. This data can be compared

to the proposed altered systems to determine if the performance is being

adversely affected.

2. Compliance Alternatives . Alternate solutions tabulated in

RS 22-2 were developed from appeal data and from acc2pted practice.

The list is not all-inclusive and should not preclude consideration

of other alternatives.

RS 22-

7
3. Analysis Methods . Analytical methods based on good engineering practice may be used to determine changes in performance levels.

4. Test Methods . Test procedures as discussed in A. 3. a. and b.

can be used to evaluate the performance of existing construction.

5. Professional Judgment . Professional judgment based on previous

experience with similar buildings should be used to the fullest extent

possible

.

8 RS 22-
Massachusetts State Building Code

REFEK£NC£ STAND/UID

RS22-2

ACCEPTABLE COMPLIANCE ALTERNATIVES

October 23, 1978

171

REFERENCE STANDARD RS22-2

ACCEPTABLE COMPLIANCE ALTERNATIVES

TABLE OF CONTENTS

I. PURPOSE AND SCOPE 1

A. Purpose 1

B. Application 1

II. COMPLIANCE ALTERNATIVES FOR EGRESS REQUIREMENTS 2

A. Number of Exits 2

B. Travel Distance 3

C. Enclosure of Exitways 3

II. COMPLIANCE ALTERNATIVES FOR FIRE HAZARDS 6

A. Fire Separations and Partitions 6

B. Openings and Exterior Wall Protection 7

173

REFERENCE STANDARD RS22-2

ACCEPTABLE COMPLIANCE ALTERNATIVES

I. PURPOSE AND SCOPE

A. PURPOSE: The purpose of this standard is to assist the building official

and those regulated by this code in judging the acceptability of compliance alternatives to specific code provisions rec[uired by the code.

B. APPLICATION: This standard contains general acceptable compliance

alternatives and examples. The examples are solely for the purpose

of illustrating principles which can be applied to the solution of

code compliance problems and eure not necessarily acceptable under all

circumstances. It is recognized that all building systems interact

with each other. Therefore, any consideration of compliance alternatives

must take into account all existing and proposed conditions to determine

their acceptability. The principles applied can be used for the solution

of similar compliance problems in other buildings and occupancy groups.

Commentaries are provided where the philosophy in establishing the

alternatives is not obvious. The examples were developed from appeal

data and accepted practice. They are not all-inclusive and should not

preclude consideration of other alternatives.

NOTE ; It is anticipated that additional con?)liance alternatives

will be added to this standard through the mechanism of

appeal decisions and from results of research being conducted by various organizations in the field of relative

performajice of life safety systems.

1 RS 22-2
II. COMPLIANCE ALTERNATIVES FOR EGRESS REQUIREMENTS

NUMBER OF EXITS

1. General Compliance Alternatives

a. Provide connecting fire balconies.

b. Provide alternate egress facilities (windows, etc.).

c. Provide a fire escape.

d. Provide fire rated areas of refuge.

2 . Exiunples

Example 1

A 5- story "row house" of occupancy group B without a fire

suppression system and with only one means of egress.

Solution A. Add one or more fire escapes as may be necessary

to provide all tenants with reasonable access to

two means of egress in separate directions.

Access to a street, public way or area of refuge

shall be provided at the termination of the fire

escape

.

Solution B. Add connecting fire balconies across fire walls

if the above solution is impractical due to construction difficulties.

Example 2

A building of group R-2 occupancy with apartment in the basement.

There is only one means of egress from the basement.

Solution A. Provide egress windows in ^ach apartment that

comply with sec. 609.4.

2 22-2
B. TRAVEL DISTANCE

1. General Compliance Alternatives

a. Add detection system.

b. Add a partial fire suppression system.

c. Add smoke doors.

d. Increase fire resistance rating of corridor walls and doors.

2. Examples

Example 1

A 4-story building of occupancy group R-2 without a fire suppression system. The length of exitway access travel is 150 ft.

Solution A. Add a partial fire suppression system off the

domestic water supply (if adequate) in the exit

access corridor.

Solution B. Subdivide corridor into segments less than 100 ft.

with smoke doors.

Solution C. If not required by other sections of the code, install

smoke and fire detectors with audible alarms in the

corridor.

Solution D. Increase the fire resistance rating of the exit

access corridor from 1 hour to 2 hours and provide

1-1/2 hour "B" label self-closing or automatic closing

fire doors in all openings onto the corridor.

C. ENCLOSURE OF EXITWAYS

1 . General Compliance Alternatives

a. Improve enclosure of exitway.

3 RS22-2
b. Add a partial fire suppression system.

c. Add a detection system.

2. Exan^les

Example 1

A 4-story row building of occupancy group R-2 with connecting fire

balconies and an interior stair. The stair is enclosed with wood

lath and plaster on wood stud partitions and paneled doors.

Solution A. Cover partitions on the apartment side with 5/8"

Type X gypsum wallboard or its equivalent. Replace or

build up panel doors until minimum solid portion is

1-3/8" and install self-closers.

Solution B. Provide a heat and smoke detection system in the

stairwell with an alarm audible to all tenants.

Provide self-closers on all stairwell doors.

Solution C. Provide a partial fire suppression system in the

stairwell of the domestic water supply (if adequate)

.

Provide self-closers on all stairwell doors.

3 . Conrmentary

The above example while pertaining to a 4-story group R-2 building

can also be applied to other buildings of various height and occupancies. The principle that the degree of compliance may not be

reduced should be remembered. If the existing enclosure is of

4 RS22-2
fire-resistive construction, it must be maintained. The primary

principle to remember, in the required enclosure of exitway, is

that an enclosure must be provided, whether fire-resistive or not,

so as to provide a smoke barrier. The purpose of providing a

smoke barrier is to prevent the passage of smoke from a fire on

one floor to the exitways and exit access corridors of other floors

and thus rendering them unusuable for egress. This principle is

illustrated by solutions A, B, & C in the aibove example.

5
ZII. COMPLIANCE ALTERNATIVES FOR FIRE HAZARDS

FIRE SEPARATIONS AND PARTITIONS

1. General Compliance Alternatives

a. Inprove fire separation.

b. Add fire suppression system.

c. Add detection system.

2. Examples

Exangle 1

A 3-story, type 3A building, of occupancy group M on the first

floor amd occupancy group B on the second and third floors. The

required separation is 3 hours.

Solution A. Add a fire suppression system to the first and

second floors.

Solution B. Add 5/8" Type X gypsum wallboard or its equivalent

to the underside of the second floor and install a

system of smoke and heat detectors with audible

alarms on the first and second floors.

Example 2

The separation between two tenants is a vood lath and plaster on

a wood studs partition. The required separation is 1 hour.

Solution A. Add 5/8** Type X gypsvan wallboard or its equivalent

to either side of the existing partition.

KS22-2
Example 3

A building of occupancy B with unrated exit access corridors.

Solution A. Install a partial fire suppression system in the

exit access corridors.

Solution B. Add 5/8" Type X gypsum wallboard or its equivalent

to either side of the corridor partition and install

self-closers on all corridor doors.

Solution C. Install a smoke and heat detection system in the

corridor with an alarm audible to all tenants on

the floor and install self-closers on all corridor

doors.

B. OPENINGS AND EXTERIOR WALL PROTECTION

1. General Compliance Alternatives

a. Add fire suppression system.

b. Improve fire resistance.

c. Remove or improve openings.

2 . Examples

Example 1

A 2-story type 4B building, of occupancy M on the first floor with

the basement and upper floors used for storage. The distance

between the building and the side lot line is 5 feet and between

it and the adjacent building is 10 feet. The adjacent building

7 RS22-2
is of type 4B construction and of occupancy group R-2. The

former occupant was a grocery store; the new occupant is a hardware store.

Solution A. Install a deluge sprinkler system along the interior

side of the wall affected.

Solution B. Add 5/8" Type X gypsum wallboard to interior side

of the wall affected.

Example 2

Same as Example 1 but with doublehung wood windows in affected wall

Solution A. Remove windows and close opening with 1-hour fireresistive construction.

Solution B. Remove windows tnd install fire windows.

Solution C. Install deluge sprinkler system as in Solution A to

Example 1.

8

RS22
Massachusetts State Building Code

REFERENCE STANDARD

RS22-3

DETAILED CLASSIFICATION OF OCCUPANCY

BY HAZARD INDEX NUMBER AND USE GROUP

October 23, 1978

RS22-3

183

REFERENCE STANDARD RS 22-3

CLASSIFICATION OF OCCUPANCY BY HAZARD INDEX NUMBER AND USE GROUP

This standard provides a more detailed guide to users of the code to

determine hazard index number and use group for various types of occupancies. It supplements Article 2*and Table 2203.8 contained in the body

of Article 22.

Hazard Index

Number Use Group

Advertising displays manufacture

including billboards S-1

Airport or other aircraft landing or

service facility (See also: Helicopter

rooftop landing facility)

Anusement park, indoor

F

A-3

Animal

Crematorium

Hospital, kennel, pound

3

2

F

B

Apartment (see Residences)

Appl iances

Manufacture

Sales

3

3

F

M

Arenas A-3

Asphalt

Processing and products manufacture H

Athletic equipment

Manufacture

Sales

3

3

F

M

Auditoriums 6,5 or 4 A-l-A, A-l-B, A-3

Automobile & other motor vehicles

Gasoline Service Station

Rental agency within a building

Repair

Repair incidental to auto sales

with limitations

2

2

3

B

B

S-1

S-1

*Massachusetts State Building Code RS22
Hazard Index

Number Use Group

Sales within a building 3 m

Wrecking 3 F

Washing 3 S-1

Awning manufacture 3 F

Baked goods shop 3 M

Bakeries 3 F

Banks 2 B

Banquet halls 5 A-3

Barber shops 2 B

Beauty shops 2* B

Beverages

Bottling 3 F

Manufacture

Alcoholic 8 H

Less than 0.5% alcohol @ 60* 3 F

oicycle

Manufacture 3 F

Rental or repair conducted

within a building 3 g.j^

Sales 3 M

Billiard parlor 4 A-3

Blacksmith shops 3 F

Blueprinting, etc., esteiblishments 3 F

Boarding house 2 R-1 or R-2

Boats or ships

Building or repair of boats 3 F

Bone distillation 3 F

Bowling alleys 4 A-3

Broom or brush manufacture 3 F

Building materials

Wholesale business in roofed structures 3 M or S-1

Bus terminals or stations 4 A-3

Business schools or colleges 4 A-4

Ca.Tiera & other photo equipment

Manufacture except film sales 3 F

Sales 3 M

2 RS22-3
Hazard Index

Hunber Use Group

Canvas or canvas products

Manufacture or repair

Carpet fc rug

Cleaning establishments

Manufacture or repair

8 or 3

3

H,F

F

Catering for outside consumption

Cemeteries

Crematory in cemetery

Mausoleum, crypt, columbarium

Mortuary chapel in cemetery

3

1

4

r

S-2

A-4

Ceramic products manufacture

Including pottery, small glazed

tile, & similar items

Charcoal, fuel; briquettes, or

lampblack manufacture H

Chemicals

Packaging

Manufacture

8 or 3 H or F depending

on nature of

materials involved

8 or 3 H or F depending

on nature of

materials involved

Churches or other places of worship

Circuses, temporary

Cleaning (see Drycleaning & Dying;

Laundries; Automobiles-washing)

4

4

A-4

A3

Clothing

Manufacturing

Rental Establishment

Retail sales

Tailoring, custom manufactiire or repair

(See also Feathers; Felt; Fur; Leather)

8 or 3

3

3

3

H or F depending

on nature of

materials involved

M

M

M

3

RS22
Hazard Index

Number Use Group

Clubs

Private

Nightclubs (see Eating & Drinking

establishments)

A

without residence

Coal, coke or tar products,

manufacture 8 H

Colleges & universities

Classroom buildings

Dormitories

Fraternities or sororities

4

2

2

A

R-1

R-1

Community centers

Convalescent homes (see Nursing homes)

Convents

Cosmetics or toiletries manufacture

Cotton ginning

Cotton wadding or linters manufacture

Ccurthouces

4 or 2

2

8

8

8

2 or 4

A-3 or B

R-1

H

H

H

B or A-3

Crematoriums

Animal

Human

Dance halls

Day Care Agencies

Day Nurseries

Dental offices (see Medical S dental)

Department stores

DozTTTiitories

Dressmaking shops, custom

Drinking places (see Eating fc drinking establishments)

Drive-in restaurants

Drive-in theaters

Drug stores

8

5

4

3

F

F

A

1-2 or A-4

1-2

R-1 or R-2

M

H

A-3

A-5

M

Dry cleaning & dyeing

Establishment

Pick up & delivery station

8 or 3 H or F depending

on solvents used

2 B

Dwellings (see Residences)

4 RS22-3
Hasard Index

Nunber Use Group

Eating or drinking places

Lunchrooms, restaurants, cafeterias,

etc. primarily enclosed 5 A-3

Drive-in 4 A-3

With entertainment or dancing 7 A2

Electric

Power or steam generating plants 3 F

Substation 3 F

Electrical appliances, bulbs, wiring

supplies, etc.

Manufacture 3 F

Sales 3 M

Electronic components & supplies

Manufacture or repair 3 F

Feathers

Curing, dyeing, washing or bulk processing 8 H

Manufacturing exclusive of above 8 H

Felt

Curing, dyeing, washing or bulk processing 3 F

Products manufacture, exclusive of above 3 F

Fertilizers, manufacture 8 H

Film, photographic manufacture 3 or 8 F or H

Storage and Studios 3 or 8 F or H

Fire station 2 B

Fish processing 3 F

Florida shops 3 M

Food

Product processing except meat 6 fish 3 F

Retail sales 3 M

Fraternities or sororities 2 R-1 or R-2

Funeral establishments 4 A-3

RS22-3
HAzard Index

Number Use Group

Fur

Curing, dyeing, finishing, tanning 8 H

Prcxiucts manufacture exclusive of above 3 F

Garage (see Peu'king garage)

Garbage incineration or reduction 3 F

Garden supplies, produce or flowers 3 M

Gas

Manufacture 8 H

Public utility stations for

metering or regulating 2 B

Storage

2500 cu. ft. or less 3 S-1

More than 2500 cu. ft. 8 H

Gasoline service stations

( s«»e Automobi les

Celetin manufacture 3 F

Generating plants, electric or steeun 3- F

Gift shops 3 M

Glass products form previously manufactured 3 F

Glue manufacture 3 F

Golf

Indoor courses or driving ranges 4 A-3

Cyrnnasiums 4 A-3

Gyi-sun manufacture 3 F

Grain storage 8 H

hair

Curing, dyeing, washing, bulk processing 3 F

Product manufacture exclusive of above 3 F

liardware

Manufacture 3 F

Retail sales 3 M

Hat bodies manufacture 3 F

Helicopter landing facility, rooftop 3 g-l

Home occupations 2 B

i-for^es for the a^ed 4 i-2

Hosiery manufacture 3 F

6

RS22-3
Hazard Index

Number Use Group

Hospitals

Including convalescent, nursing or rest

homes, and sanitoriuns, provided

custodial care is not provided for

drug addicts, alcoholics, or mentally

ill or mentally deficient 4 1-2

For care of drug addicts, mentally

ill or mentally deficient 5 I-l

Research or teaching laboratories

(see also Animals-Hospitals) 2 B

Hotels 2 R-1

Ice manufacture (dry or natural) 3 F

Ice skating rinks 4 A-3

Incineration or reduction of garbage,

offal, or dead animals 3 F

Industrial uses (see specific items)

Without resulting noise, vibration,

special danger, hazard, dust,

smoke, fumes, etc. 3 F

Other than above 3 or 8 F or H

Ink or inked ribbon manufacture 3 F

Jewelry 3 F

Kennels (see Animals)

Laboratories

Research laboratory not accessory

to school or hospital 2 B

Scientific research or teaching

laboratory, non-profit, accessory

to school or hospital subject to

limitations 2 B

Laundries

Hand laundry 2 B

Self service; Pick up & delivery

station of laundry or dry cleaner 2 B

Steam laundries without limitations 3 F

7 RS22-3
HAzard Index

Number Use Group

Z<eather

Curing, dyeing, finishing or tanning 3 F

Product manufacture exclusive of above 3 F

Libraries 4 A-3

Linoleum or oilcloth manufacture 3 F

Liquor sales, package 3 M

Luggage manufacture 3 F

Lumber (see Wood)

Manufacturing 3 or 8 F or H

Matches manufacture 8 H

Mattresses manufacture and renovation 3 F

Meat

Markets 3 M

Slaughtering or packaging 3 F

Medical & dental

Offices 2 B

(see also Laboratories; Orthopedic

and medical appliances; Hospitals)

Meeting hall 4 A-3

Metals, manufacture 3 F

Reduction, refining or smelting 8 H

Monasteries 2 R-1

Motels 2 R-1

Motor freight stations

(sec Trucking terminals)

Museums 4 A-3

Musical instruments manufacture 3 F

Newspaper publishing 3 F

Newsstands 3 M

Novelty products manufact\u:e 3 F

Nursing homes 4 1-2

Offices 2 B

Oilcloth manufacture 3 F

Optical equipment or similar

precision instruments manufacture 3 F

RS22
Hazard Index

Nuaber Use Group

Orphanages Z-2

Orthopedic or medical appliances manufacture 3 P

Paint, turpentine or varnish

Manufacture 8 M

Spraying booths 8 H

Paper products manufacture 3 P

Parish houses 4 A-3

Parking garages 3 S-1

Petroleum or petroleum products

Refining 8 H

Storage 3 S-1

Pharmaceutical products manufacture 3 F

Photographers studio 2 B

Plastics

Products manufacture 8 H

Raw, manufacture 8 H

Police Stations 2 B

Pool rooms 4 A-3

Post offices 2 B

Printing

Plant 3 F

Printing or newspaper publishing 3 F

Prisons & other correctional or

detention institutions 5 I-l

Pumping station or substation,

water or sewage 2 B

f

Radio

Sales 3 M

Studios with audience 5 A-l-B

Studios without audience 2 B

Railroad

Freight terminal 3 S-1

Passenger station 4 A-3

9 RS22-3
Hazard Index

Number Use Group

Recreation

Center, indoor 4 A

CoRununity center building 4 A-S

Rectories 2 R-1

Residences

One- family '2 R-3

Two- family 2 R-3

Apartment 2 R-2

Temporary dwelling structure 2 R-3

Boarding or lodging house 2 R-1 or R-2

Dormitory 2 R-1 or R-2

Fraternity or sorority 2 R-1 or R-2

Hotel, motel, apartment hotel with

accessory services 2 R-1

Convents, monasteries, rectories 2 R-l

Research laboratories (see Laboratories)

Restaurant, lunch room, cafeteria or

other establishment primarily for eating 5 A-3

Retail business 3 M

Stores with combustible or flaunmable

goods constituting a high hazard 8 H

Rubber

Manufacture (natural or synthetic)

including tires, tubes or

similar products 8 H

Products (exclusive or processing)

including washers, gloves,

footwear, bathing caps and like 3 F

Sanatoriums

Not providing custodial care -for drug

addicts, alcoholics or mentally ill

or mentally deficient 4 1-2

Providing care for above 5 I-l

Schools 4 A-4

Seminaries 4 t 2 A-4 & R-1

10 RS
Hazard Index

Number Use Group

Settlement houses (depending on

nature of activities)

Sewage

Disposal plant

Pumping station

4 or 2

3

3

A-3 or B

F

F

Shoddy manufacture 8

Shoes

Manufacture

Repair shop

3

2

F

B

Silverware, manufacture, plate or sterling

Size manufacture

Skating rinks

3

3

4

F

A3

A3

Soap & detergents

Manufacturing, including fat rendering

Packaging

8

3

H

F

Solvent extracting 8

Sporting or athletic goods

Manufacture

Stores

3

3

F

M

Stables 3

Stadiums 4

Wholesale business including accessory

storage other than flaunmable liquids,

gases and explosives, in roofed structures 3 or 1

Stores (see Retail stores; or specific items)

S-1

A5

S-1 or S-2 depending

on nature of materials involved

Tailor shops, custom

Tanning (see Leather; Fur)

Taxidermist shops

2

3

B

M

Telephone exchanges

Automatic

Son automatic

2

2

B

B

11 RS22-3
Hazard Index

Number Use Group

Television

Sales

Studios

Texti les

Manufacture, including knit goods, yard

goods, thread or cordage; spinning,

weaving, dyeing and printing

Shoddy, manufacture

3

6

5

2

3

8

M

A-la with scenery

A-lb no scenery

B no audience

F

H

Theaters 6

5

A-la with scenery

A-lb no scenery

motion picti:re

Tires, manufacture 8

Tobacco products manufacture including curing 3

H

F

Tools and hardware

Kanu facture

Sales

3

3

F

M

Toys

Manufacture

Trailer park (see also Mobile homes)

Truck

Repairs

Sales

3

3

S-1

M

Trucking terminals

Turpentine manufacture

3

8

S-1

H

Warehouses 8, 3, or 1 H, S-1, or S-2

depending on nature

of materials involved

Waterpumping stations

Wax products manufacture

2

8

B

H

12 RS22-3
Hazard Index

Number Use Group

Wholesale

Office, display or sales space

Storage, other than flammable

liquids or gases and explosives,

in roofed structures 3 or 1

B

storage restricted

to samples

S-1 or S-2

depending on nature

of material involved

Window shades memufacture

Wood

Distillation

Products manufacture, including

furniture, boxes, crates, barrels,

baskets, pencils and the like

Pulp or fiber reduction or

processing, including paper

mill operation

Sales

Sawnills

8

3

3

8

H

P

M

H

Wool scouring or pulling

Umbrellas, manufacture

Upholstering

3

3

3

F

P

P

Vehicles

Manufacture

Venetian blinds, window shades &

awnings, manufacture

13 RS 22-
41
Massachusetts State Building Code

REFERENCE STANDARD

RS22-4

ARCHAIC CONSTRUCTION SYSTEMS

October 23, 1978

199

RS22
II
REFERENCE STANDARD RS22-4

ARCHAIC CONSTRUCTION SYSTEMS

Table of Contents

Page

I. PURPOSE AND SCOPE 1

A. Purpose 1

B. Scope 1

C. Application 1

II. ARCHAIC FIRE-RESISTIVE SYSTEMS 2

A. Fire-Resistive Materials and Construction 2

B. Fire-Protection of Steel Columns 5

C. Fire-Protection of Cast Iron Columns 6

D. Fire-Protection of Steel in Reinforced Concrete Columns ... 7

E. Fire-Protection of Steel Beams / Girders and Trusses 7

F. Fire-Protection of Steel in Reinforced Concrete 8

G. Fire-Protection of Steel in Reinforcing in Floors and Roofs . 9

H. Fire-Resistiv."* Floor and Roof Construction 9

I. Fire-Resistive Ceiling Construction 10

J. Fire-Resistive Bearing Walls and Partitions 11

K. Fire-Resistive Non-Bearing Walls and Partitions 13

L. Fire-Resistive Doors 14

M. Fire Door Construction 17

N. Fire-Resistive Shutters .... 18

0. Fire-Resistive Windows 18

P. Fire- Resistive Roof Covering 20

REFERENCE STANDARD RS 22-4

ARCHAIC CONSTRUCTION SYSTEMS

I. PURPOSE AND SCOPE

A. PURPOSE. The purpose of this standard is to assist the building

official and those regulated by this code in evaluating the properties of archaic construction systems.

B. SCOPE. This standard contains data on construction systems no longer

in general use but which may be encountered in older existing buildings. It is meant to be used for assessing existing conditions when

evaluating how proposed changes are impacting the performance of the

building.

C. APPLICATION. In any given problem, all available data shall be synthesized and professional judgment exercised in arriving at decisions.

Evaluative judgment shall be used when test data does not exist or

when applying the data contained in this standard.

1

RS 22-4
II. APCHAIC FIRE RESISTIVE SYSTEMS

This standard contains a list of fire-resistive materials and construction

ifhich are not necessarily currently in common use. Some of the hourly

ratings contained in the listing predate ASTM E-119 that is in current

use. The hourly ratings may be higher or lower if tested according to

ASTM E-119. In addition to the data contained herein, see Report BMS92,

Building Materials and Structures , dated October 7, 1942, National Bxireau

of Stemdards. The data listed below is extracted from the Boston Building

code, circa 1943.

A. FIRE-RES I STIVE MATERIALS AND CONSTRUCTION

(a) Materials, to be given the fire-resistive ratings specified in

this part, shall have the following minimum qualities:

(1) Concrete of Class 1 shall be so proportioned as to have a strength of at least fifteen hundred pounds per square inch and the

coarse aggregate sh<Lll consist of limestone, trap rock, blast furnace

slag, cinders containing not more than twenty per cent of combustible

material, burned clay or shale.

(2) Concrete of Class 2 shall be so proportioned as to have a strength of at least fifteen hundred pounds per square inch, the

coarse aggregate consisting of seuidstone, granite, quartzite, siliceous gravel or other similar material not over one inch in size.

(3) Masonry laid in lime-cement or cement mortar, or approved

masonry cement mortar, except that masonry of gypsum tile shall,

and masonry of structural clay tile may, be laid in gypsum mortar.

Masonry shall be thoroughly bonded by breeJcing joints in successive

courses or by the use of metal ties.

(4) Brick shall be burned clay or shale, concrete or samd-lime

brick of Grade C or better.

(5) Stone shall be limestone, marble, slate or equally fireresistive natural stone. Sandstone, granite or other stone which,

because of its crystalline structure or for other reason, is less

fire-resistive, shall not be considered fire-protection for structural metal, but may be used in a masonry wall not less than twelve

inches thick required to have fire-resistance. Stone masonry shall

have the same fire-resistive rating as brick masonry.

(6) Cast stone masonry shall have the same fire-resistive rating

as brick masonry.

(7) Concrete blocks, whether solid or hollow, shall have as

coarse aggregate limestone, trap rock, blast furnace slag, cinders

containing not more than twenty per cent of combustible material,

burned clay or shale.

(8) Structural clay tile shall conform to the specifications for

load-bearing tile, floor tile or partition tile. Where paurtition tile

is specified, load-bearing tile may be used.

RS 22-4

2
(9) Gypsum tile or pre-cast gypsum concrete, whether solid or

hollow, shall conform to Standard Specifications for Gypsum Partition

Tile or Block of the American Society for Testing Materials and shall

not contain more than three per cent by %^ight of wood or other combustible binder or filler.

(10) Gypsum concrete shall not contain more than twelve and

one-half per cent by weight of wood or other combustible binder or

filler, and shall have a compressive strength of at least five

hundred pounds per square inch. It shall not be used where exposed

to the elements.

(11) Expanded metal or wire lath as a base or reinforcement for

plastering shall weigh not less than two and two-tenths pounds per

square yard and shall have not less than two and one-half meshes per

inch.

(12) Metal mesh reinforcement specified for masonry fire protection of structural metal shall consist of wire lath strips the full

thickness of the masonry, laid in the beds thereof, or its approved

equivalent.

(13) Metal mesh reinforcement specified for concrete fire protection of structural metal shall consist of wire mesh weighing not less

than one and one-half pounds per square yard with wire spaced not over

four inches, or not less than number eleven gage steel wire spaced not

over four inches apart, or its approved equivalent.

(14) Cement plaster shall be proportioned of one part Portland

cement, and not more than two parts of sand measured by volume dry and

loose to which may be added lime putty or hydrated lime not exceeding

fifteen per cent of the cement.

(15) Gypsum plaster, except where otherwise specified, may contain sand not in excess of three times the weight of the gypsum.

(16) Lime plaster shall consist of a mixture of one part line, not

over three parts sand, and water.

(17) Pneumatically projected mortar made of Portland cement, sand

and water shall be rated for fire-protection the same as Class 1 concrete.

(18) Concrete fill, where specified in this chapter in connection

with hollow masonry units, shall consist of Class 1 or Class 2 concrete

poured in the hollow spaces of the units as they are laid.

(b) Portland cement concrete or gypsum concrete poured in place as

fire-protection for beams, trusses and other horizontal or inclined

3 RS22-4
neB\bers of sti^cturAl steel and pneumatically projected mortar applied to

structural steel as fire-protection shall be reinforced with metal mesh

reinforcement. Concrete protection for vertical columns of structural

netal shall have reinforcing consisting of number five wire spaced not

over eight inches apart or its equivalent. Reinforcement shall be

wrapped around the structural member and so arranged as to be completely

embedded in the fire-protective material and to ensure its integrity.

(c) Plaster used as fire-protection or to resist the spread of fire

shall be reinforced with metal lath, except plaster less than one inch

thick on masonry or concrete.

(d) In the protection of structural metal including reinforcement,

one-half inch of cement or gypsum plaster may replace an equal thickne

of poured concrete or pneumatically projected mortar as protective material; and one inch of cement or gypsum plaster reinforced with metal

lath may replace an equal thickness of poured concrete, pneumatically

projected mortar or masonry protection.

(e) Where plaster is required without other specification, it shall

consist of one-half inch of cement or gypsum plaster, except that only

gypsum plaster shall be used on gypsum masonry.

(f) In this chapter, except where othervise specifically stated,

the thickness given in a list of materials applies to the next following item only, and not to the total thickness where additional materials

are specified.

(g) Pipes, wires, conduits and ducts shall not be embedded in or

placed behind the fire-protective materials required for the protection

of structural steel or iron except as otherwise provided in this paragraph. Above fire-protective hung ceilings and within the enclosed

space in buildings of Type 1 and Type 2 construction, within which,

other than the enclosure, fire protection of steel is not required,

pipes, wires, conduits and ducts may be placed, provided they are so

arranged and so secured that they will not, either by expanding in the

event of fire, or otherwise impair the effectiveness of the enclosing

protective materials. Electric conduits and wires and gas pipes may be

embedded in concrete or masonry fire protection of structural steel

where the protective material is reinforced with wire mesh, provided

they shall have protective covering except over the tops of beeims and

girders, at least as thick as required for the steel.

(h) In factories, garages, warehouses and other buildings in which

the fire-protective covering required for steel or iron columns may be

injured by the movement of vehicles, materials or equipment, the

4 RS22
such covering shall be protected by metal or other material in a manner

satisfactory to him.

(i) rire-stopping shall mean the

stopping-off or enclosure at the ends and wherever else specified of

the spaces between studs of partitions, joists of floors and roofs and

other similar spaces to prevent drafts of air and the communication of

fire from one such space to another. Fire-stopping shall consist of

vfood not less than one and one-half inches thick, of sheet metal not

less than twenty- four gage or of masonry, or a combination of such

materials. Fire-stopping shall be tightly fitted in the space to be

filled, about pipes, wires and ducts and if cut or disturbed in the

placement of pipes, wires and ducts shall be repaired.

FIRE-PROTECTION OF STEEL COLUMNS

(a) Structural steel columns required to have fire-protection of a given rating shall be covered on all sides, with protective material

having not less than the thickness necessary for the required rating.

Except where "no fill" is specified, re-entrant and other accessible

spaces behind the specified outer protection shall be filled with concrete or brick masonry or the material of the outer protection.

(b) The following materials shall be assumed to afford to steel

colu.T-n3 fire-protection of the rating indicated:

Four-hour rating:

(1) Two inches Class 1 concrete.

(2) Three inches Class 2 concrete, metal mesh reinforcement.

(3) Three and one-half inches brick masonry.

(4) Two layers two-inch structural clay partition tile masonry,

metal mesh in beds.

(5) Two inches structxiral clay partition tile masonry, concrete

fill, metal mesh in beds, three-fourths inch gypsum plaster.

(6) Four inches structural clay partition tile masonry, concrete fill, metal mesh in beds, five-eighths inch lime plaster.

(7) Four inches structural clay partition tile or concrete

block masonry, concrete fill, plaster.

(8) Three inches hollow gypsum tile masonry and plaster.

(9) Two inches gypsum concrete, metal mesh reinforcement.

(10) Two inches solid gypsum tile masonry and plaster.

(11) Three inches solid cinder concrete block masonry and plaster.

(12) Four inches hollow cinder concrete block masonry and plaster.

Three-hour rating:

(13) One and three-fourths inches Class 1 concrete.

(14) Two inches Class 2 concrete, metal mesh reinforcement.

5 RS22-4
(15) Two inches gypsum concrete.

(16) Two inches solid cinder concrete block masonry and plaster.

(17) Two inches structural clay partition tile masonry, concrete

fill.

Two- hour rating:

(18) One and one-half inches Class 1 concrete.

(19) Two inches Class 2 concrete, metal mesh reinforcement.

(20) One inch Class 1 or Class 2 concrete encased in standard

weight steel or %nrought iron pipe.

(21) Two inches structural clay partition tile masonry and

plaster.

(22) Two layers plaster, each on metal lath, with three-fourths

inch air space between, two inches total thic)cness.

(23) Two-inches gypsum concrete.

(24) Two inches solid or three inches hollow gypsum tile masonry.

One-hour rating:

(25) One inch Class 1 concrete.

(26) One and one-half inches Class 2 concrete with metal mesh

reinforcement.

(27) Two and one-fourth inches brick masonry.

(28) Two inches structural clay partition tile or concrete block

masonry.

(29) One inch cement or gypsum plaster on metal' lath.

(c) The thickness of protection on the outer edges of lugs or brackets

need not exceed one inch.

FIRE-PROTECTION OF CAST IRON COLUMNS

(a) Cast iron columns required to have fire-protection of a given

rating shall be covered on all sides with protective materials having

not less than the thickness necessary for the required rating. Re-entrant spaces, if any, on the exterior of cast iron columns, and other

accessible spaces behind the specified protection, shall be filled with

Class 1 concrete or brick masonry or the material of the outer protection.

(b) The following materials shall be assumed to afford to cast iron

columns fire-protection of the rating indicated:

Four-hour rating:

Cast iron columns shall not be used where protection of four-hour

rating is required.

Three-hour rating:

(1) Two inches Class 1 concrete.

(2) Three inches Class 2 concrete, metal mesh reinforcement.

6 RS22-4
(3) Two inches structural clay partition tile or concrete

block masonry concrete fill.

(4) One and one-half inches cement or gypsum plaster on metal

lath and metal furring to form one-half inch air space.

(5) One and one-half inches Class 1 concrete.

(6) Two inches Class 2 concrete with metal mesh reinforcement.

One-hour rating:

(7) One inch Class 1 concrete.

(8) One and one-half inches Class 2 concrete with metal mesh

re inforcement

.

(9) One inch cement or gypsum plaster on metal lath.

D. FIRE-PROTECTION OF STEEL IN REINFORCED CONCRETE COLUMNS

(a) The main steel reinforcement, including spiral reinforcement

and ties larger than one-half inch, in reinforced concrete columns

required to have fire-protection of a given rating shall be covered

with concrete having not less than the thickness listed in this section

for the rating indicated:

Four- hour rating:

(1) One and one-half inches Class 1 concrete.

(2) Two inches Class 2 concrete.

Three-hour rating:

(3) One and one-half inches Class 1 or Class 2 concrete.

Two-hour rating:

(4) One inch Class 1 concrete.

(5) One and one-half inches Class 2 concrete.

One-hour rating:

(6) One inch Class 1 or Class 2 concrete.

(b) The thickness of protection on column ties not larger than onehalf inch may be one-half inch thinner than that listed above.

E. FIRE-PROTECTI ON OF STEEL BEAMS, GIRDERS AND TRUSSES

(a) Steel beams, girders and trusses or the members of trusses,

required to have fire-protection of a given rating, shall be covered

on all sides with material having not less than the thickness necessary

for the required rating.

(b) The following materials shall be assumed to afford steel beams,

girders and trusses, or the members thereof, fire-protection of the

rating indicated:

Four-hour rating;

(1) Two inches Class 1 concrete.

7 FS22
(2) Three Inches Class 2 concrete.

(3) Three inches structural clay partition tile or concrete

block masonry and plaster.

(4) Three inches hollow gypsum tile masonry and plaster.

(5) Two inches gypsum concrete.

(6) Two inches solid gypsum tile masonry and plaster.

Three-hour rating:

(7) One and three-quarters inches Class 1 concrete.

(8) Two and one-half inches Class 2 concrete.

(9) Two inches gypsum concrete.

(10) Two inches structural clay partition tile, or concrete

block masonry and plaster.

(11) Two inches solid, or three inches hollow gypsum tile masonry.

Two-hour rating:

(12) One and one-half inches Class 1 concrete.

(13) Two inches gypsum concrete.

(14) Two inches gypsum concrete.

One-hour rating:

(15) One inch Class 1 concrete.

(16) One and one-half inches Class 2 concrete.

(17) Seven-eighths inch cement or gypsum plaster on metal lath.

FIRE-PROTECTION OF STEEL IN REINFORCED CONCRETE BEAMS.

(a) The main steel reinforcement, including stirrups larger than

one-half inch, in reinforced concrete beaxns , girders and trusses, including the ribs of reinforced concrete ribbed floors or roofs where one or

both sides of the ribs, in addition to the soffit, are exposed to fire,

required to have fire-protection of a given rating, shall be covered on

all sides with concrete having not less than the thickness listed in

this section for the required rating. Where a reinforced concrete

floor or roof has a flush ceiling formed with approved permanent masonry

fillers between ribs, the reinforcement shall have the protection required for reinforcing steel of floors and roofs in section G.

Four-hour rating:

(1) One and one-half inches Class 1 concrete.

(2) Two inches Class 2 concrete.

Three-hour rating:

(3) One and one-half inches Class 1 or Class 2 concrete.

Two- hour rating:

(4) One inch Class 1 concrete.

(5) One and one-half inches Class 2 concrete.

One-hour rating:

(6) One inch Class 1 or Class 2 concrete.

8 RS22-4
(b) The thickness of protection on stirrups not larger than

one-half inch may be less than that listed by not more than one-half

inch.

G. FIRE-PROTECTION OF STEEL REINFORCING IN FLOORS AND ROOFS

(a) The steel reinforcement in reinforced concrete floors and roofs

with flush or plane ceilings, such that the exposure to fire is on the

soffit only, required to have fire-protection of a given rating, shall

be covered with concrete having not less than the thickness listed in

this section for the required rating. In floors or roofs having reinforced concrete ribs where the concrete surrounding the steel reinforcement is exposed to fire on one or both sides in addition to the soffit,

such reinforcement shall have the protection specified in section F

for steel in reinforced concrete beams.

Four-hour rating:

(1) One inch Class 1 concrete.

(2) One and one-fourth inches Class 2 concrete.

Three-hour rating:

(3) One inch Class 1 or Class 2 concrete.

Two-hour rating:

(4) Three-fourths inch Class 1 concrete.

(5) One inch Class 2 concrete.

One-hour rating:

(6) Three-fourths inch Class 1 or Class 2 concrete.

H. FIRE- RESISTIVE FLOOR AND ROOF CONSTRUCTION

(a) Floors and roofs required to have resistance of a given rating

to the spread of fire shall have such thickness of the materials of

which it is constructed, as shall be necessary for the required rating,

and structural metal forming a part of such floors or roofs shall have

protection against fire of such required rating. Floors and roofs

required to have two-hour or longer resistance to fire shall be constructed of incombustible materials. Granolithic, burned clay tile,

ceramic tile or other similar incombustible floor finish of a given

thickness may be substituted for an equal thickness, and sand, cinder

or other incombustible filling material, with or without embedded

wooden screeds, may be substituted for two-thirds its thickness, of

the floor or roof construction material specified in this section;

provided, that such floors and roofs shall have adequate thickness

for structural purposes.

(b) The following floor or roof construction shall be assumed to

afford resistance to the spread of fire of the rating indicated:

9

RS 22-4
Four-hour rating:

(1) Four inches solid slab of reinforced Portland cement

concrete or reinforced precast gypsum concrete.

(2) Pour inches solid masonry arches or slabs.

(3) Four inches structural clay floor tile masonry arches or

slaibs with top covering of not less than two inches of solid masonry

or reinforced concrete.

(4) Five inches combination reinforced Portland cement concrete slab consisting of permanent fillers of concrete block, gypsum

or structural clay tile and one and one-half inches of concrete

topping; but if structural clay partition tiles are used for fillers

they shall be plastered on the soffit.

Three-hour rating:

(5) Three inches solid slab of reinforced Portland cement

concrete or reinforced precast gypsum concrete.

(6) Three inches solid masonry arches or slabs.

(7) Four inches structural clay floor tile masonry, arches

or slabs with top covering of not less than one and one-half inches

of solid masonry or reinforced concrete.

(8) Four inches combination reinforced Portland cement concrete

slab consisting of permanent fillers of concrete block, gypsum or

structural clay tile and one-inch concrete topping; but if structural

clay partition tiles are used for fillers, they shall be plastered on

the soffit.

Two-hour rating:

(9) Two and one-half inches solid slab of reinforced Portland

cement concrete or reinforced precast gypsum concrete.

(10) Two and one-half inches solid masonry arches or slabs.

(11) Three inches structural clay floor tile masonry, arches

or slabs with top covering of not less than one inch of solid masonry

or reinforced concrete.

One-hour rating:

(12) Three inches structural clay floor tile masonry, arches or

slabs with all joints thoroughly filled with cement or gypsum mortar.

(13) Wood floor or roof construction with joists not less than

one and five-eights inches in least dimension, fire-stopped, double

board floor, approved asbetos felt between layers of boards, and

with a ceiling of at least three-quarters inch cement or gypsum

plaster on metal lath.

(14) Steel beauns or steel joists not more than thirty-six inches

apart on centers with incombustible floor and a ceiling of at least

three-fourths inch cement or gypsum plaster on metal lath metal

furring.

F I R£- RES I STIVE CEILING CONSTRUCTION

(a) Ceilings required to afford fire-protection of a given rating

10

RS22-4
to the floor or roof framing under which it is supported shall be of

fire-resistive materials of at least the thickness necessary for the

given rating. A fire-resistive ceiling and all hangers and fastenings

necessary for its support to the protected framing shall be of incombustible materials. It shall be capable of sustaining its ovm weight

without exceeding allowable stresses. Metal reinforcement in such a ceiling shall be protected from fire as specified in section G for

reinforcing in a floor.

(b) The following ceiling construction shall be assumed to afford

to floor or roof framing fire-protection of the rating indicated:

Four-hour rating:

(1) Two and one-half inches solid slab of reinforced Portland

cement concrete or reinforced precast gypsum concrete.

(2) Two inches precast reinforced gypsum concrete, plastered.

Three-hour rating:

(3) Two inches solid slab of reinforced Portland cement concrete or reinforced precast gypsum concrete.

(4) Two inches precast reinforced gypsum concrete/ lapped or

rabbeted joints.

Two-hour rating:

(5) One and one-half inches solid slab of reinforced Portland

cement concrete or reinforced precast gypsum concrete.

One-hour rating:

(6) Three-fourths inch cement or gypsum plaster on metal lath.

FIRE-RESISTIVE BEAJIING WALLS AND PARTITIONS

(a) Bearing walls and partitions required to have resistance to

fire or the spread of fire of a given rating shall be constructed of

fire-resistive materials and shall have at least the thickness necessary

for the required rating. Walls required to have two-hour or longer

rating shall be of incombustible materials. Steel reinforcement in

reinforced concrete walls shall have the same protection for the given

rating as is required in section G in floors.

(b) Bearing walls and partitions of the following construction and

thickness shall be assumed to have resistance to fire and the spread

of fire of the rating indicated;

Four-hour rating:

(1) Eight inches solid brick masonry.

(2) Twelve inches hollow wall of brick masonry, minimum eight

inch masonry thickness.

(3) Twelve inches structural clay load-bearing tile masonry

with two units and not less than three cells in the thickness of the

wall.

11 RS22-4
(4) Eight Inches structural clay load-bearing tile masonry

with one unit and not less than two cells in the thickness of the

wall, plastered both sides.

(5) Twelve inches concrete block masonry with one unit and

not less than tvo cells in the thickness of the wall.

(6) Eight inches one-piece concrete block masonry with shells

and webs at least one and one-half inches thicks plastered both

sides.

(7) Twelve inches total thickness of brick masonry facing

bonded to structural clay load-bearing tile masonry backing.

(8) Eight inches solid concrete.

(9) Six inches solid reinforced concrete.

(10) A steel or reinforced concrete frame bearing wall in

which the steel has fire-protection of four-hour rating, with panel

filling as specified in section K for a non-bearing wall of fourhour rating.

Three-hour rating:

(11) Eight inches structural clay load-bearing tile masonry

with two units and not less than four cells in the thickness of the

wall.

(12) Twelve inches structural clay load-bearing tile masonry

with one unit and not less than three cells in the thickness of

the wall.

(13) Eight inches one-piece concrete block masonry with shells

and webs not less than one and one-half inches thick, plastered

both sides.

(14) Eight inches one-piece concrete block masonry with shells

and webs not less than two inches thick.

(15) Five inches solid reinforced concrete.

(16) A steel or reinforced concrete frame bearing wall in

which the steel has fire-protection of three-hour rating, with

panel filling as specified in section K for a non-bearing wall of

three-hour rating.

Two-hour rating:

(17) Eight inches structural clay load-bearing tile masonry

with not less than three cells in the thickness of the wall.

(18) Eight inches concrete block masonry with shells and webs

not less than one and one-half inches thick.

(19) A steel or reinforced concrete fraune bearing wall in

which the steel has fire-protection of two-hour rating, with panel

filling as specified in section K for a non-bearing wall of two-hour

rating.

One-hour rating:

(20) A steel or wooden stud bearing wall covered on both sides

with one-inch cement or gypsum plaster on metal lath, fire-stopped,

if of wood.

12

RS2
(21) A Steel or reinforced concrete frame bearing wall in

which the steel has fire-protection of one-hour rating, with panel

filling as specified in section K for a non-bearing wall of onehour rating.

FIRE- RES J STIVE NON-BEARING WALLS AND PARTITIONS

(a) Non-bearing walls and partitions required to have resistance

to fire and the spread of fire of a given rating shall be constructed

of fire-resistive materials and shall have at least the thickness

necesseury for the required rating. Walls required to have two-hour

or longer rating shall be of incombustible materials. Steel reinforcement in reinforced concrete walls shall have the same protection for

the given rating as is required in section G for steel in floors.

(b) Non-bearing walls and partitions of the following construction

and thickness shall be assumed to have resistance to fire and the

spread of fire of the rating indicated:

Four-hour rating:

(1) Eight inches solid brick masonry.

(2) Three and one-half inches solid brick masonry, plastered

both sides.

(3) Six inches structural clay load-bearing tile, plastered

both sides.

(4) Six inches solid concrete.

(5) Four inches solid reinforced concrete.

(6) Any wall which, as a bearing wall, has a three-hour or

four-hour rating in section J, except the steel or reinforced concrete frame bearing wall.

Three-hour rating:

(7) Three and one-half inches solid brick masonry.

(8) Four inches structural clay load-bearing tile, plastered

both sides.

(9) Four inches solid concrete.

(10) Three inches reinforced concrete.

(11) Any wall which, as a bearing wall, has a two-hour ratine

in section J, except the steel or reinforced concrete frame bearing

wall.

Two-hour rating:

(12) Three inches gypsum tile masonry, plastered both sides

except in exterior walls.

(13) Eight inches structural clay partition tile masonry,

plastered both sides.

(14) Eight inches structural clay load-bearing tile, with

three cells in the thickness of the wall.

(15) Four inches concrete block plastered both sides.

13 RS22-4
(16) Two inches solid neat, fibered, gypsum plaster on metal

lath and incombustible studding.

One-hour rating:

(17) Three inches gypsum tile masonry.

(18) Two inches solid gypsum tile masonry plastered both sides.

(19) Three inches structural clay partition tile plastered

both sides.

(20) Two and one-half inches solid cement or sanded gypsum

plaster on metal lath and incombustible studding.

(21) Three inches total thicJcness of hollow wall, three-fourths

inch cement or gypsum plaster on metal lath and incombustible studding

(22) Three inches total thickness of hollow wall, three-fourths

inch cement or gypsum plaster on metal lath and wooden studding,

fire-stopped

L. FIRE- RES I STIVE DOORS

(a) Doors which are required to be fire doors, fire-resistive doors,

or of fire-resistive construction shall conform to the requirements

of this section and section M.

(b) Fire doors shall be classified for the purposes of this code

as Class A, Class B, and Class C.

(c) Class A fire doors shall be doors of the following construction

as specified in Section M.

(1) Tin-clad, three-ply wood core, sliding.

(2) Tin-clad, three-ply wood core, swinging single leaf,

doorway not over six feet wide.

(3) Tin-clad, three-ply wood core, swinging in pairs, doorway

not over ten feet wide.

(4) Hollow metal, swinging single leaf, doorway not over four

feet wide.

(5) Hollow metal, swinging in pairs, doorway not over eight

feet wide.

(6) Sheet metal, sliding, single, doorway not over ten feet

wide

(7) Sheet metal, sliding in pairs, doorway not over twelve

feet wide.

(8) Sheet metal, swinging single leaf, doorway not over six

feet wide.

(9) Sheet metal, swinging in pairs, doorway not over ten

feet wide.

(10) Steel rolling, doorway not over twelve feet wide.

14 RS 22-4
(11) steel plate, doorway not over four feet wide.

(12) Any other construction equal or superior to a tin-clad

three-ply vrood core door in a standard fire test, for resistance

to fire, the spread of fire and smoke, and transmission of heat.

(d) Class B fire doors shall be doors of the following construction

as specified in section M.

(13) Tin-clad, three-ply wood core.

(14) Tin-clad, two-ply wood core, sliding, doorway not over

ten feet wide.

(15) Tin-clad, tv#o-ply wood core, swinging single leaf, doorway not over six feet wide.

(16) Tin-clad, two-ply wood core, swinging in pairs, doorway

not over ten feet wide.

(17) Hollow metal, sliding, doorway not over eight feet wide.

(18) Metal-clad, paneled, swinging single leaf, doorway not

over three feet wide.

(19) Metal-clad, paneled, swinging in pairs, doorway not over

six feet wide.

(20) Any other construction equal or superior to a tin-clad

two-ply wood core door in a standard fire test, for resistance to

fire, the spread of fire and smoJce, and transmission of heat.

(e) Class C Fire doors shall be doors of the following construction

as specified in section M.

(21) Metal-clad, paneled, swinging single leaf, doorway not

over four feet wide.

(22) Metal-clad, paneled, swinging in pairs, doorway not

over eight feet wide.

(f) A Class A door may be used where Class B or Class C is specified; a Class B door may be used where Class C is specified. Two

Class B or Class C doors on opposite sides of the wall may be used

where a single Class A or Class B door is specified.

(g) Fire-resistive doors, when closed, shall completely cover the

doorways in the walls and partitions or the openings in the floors or

roofs to which they are fitted. A swinging fire door shall either

overlap both jambs and the head of the opening not less than four

inches or be fitted to a fire-resistive fraone with a rabbet the full

thickness of the door and with not less than one half inch overlap on

the door. A sliding fire door, except in enclosures about passenger

elevators, shall overlap both jambs and the head of the opening not

less than four inches. A sliding fire door in an enclosure adxsut a passenger elevator shall overlap jambs, head and adjoining panels not

less than one half inch. Fire doors shall fit closely at the floor

with clearance of not over one quarter inch.

15 RS 22-4
(h) In buildings wi.ih combustible floors, doorways required to

have fire doors shall have incombustible thresholds the full thickness

of the wall, extending at least four inches from the face of the wall

where a door is hung and extending laterally at least six inches

behond each jamb of the doorway. Thresholds may be flush with the

floor.

(i) The rabbeted frame of a swinging fire door shall be constructed

of structural steel built into the concrete, masonry or other fireresistive material of the wall about the opening and secured thereto,

except that the rabbeted frame of a Class B or Class C door may be of

wood, covered with sheet metal not less than twenty-six gage in

thickness, secured to the wall in the opening.

(j) Fire doors when closed shall fit tightly against the wall or

frame so as to provide an effective stop for fire and smoke. Except

for the metal-covered wooden frame specified in this section, combustible

material shall not intervene between the door and the fire-resistive

material of the wall, floor or roof to which it is fitted.

(k) Hinge hardware for fire doors shall be of malleable iron or

rolled structural steel not less than one fourth inch thick except

that tubular steel track for sliding doors may be not less than one

eighth inch thick. Equivalent thickness of solid bronze or brass may

be used. Fire doors shall not /depend upon cords, caJbles or chains to

support them in closed position except in elevator shafts.

(1) Tracks for sliding fire doors shall be so supported that a

track hanger comes at each door hanger when the door is closed. Track

hangers shall be secured to wood stud walls by screws or bolts, to

steel stud walls by bolts or rivets, to masonry walls by through bolts

and to concrete walls by through bolts or approved built-in inserts.

Expansion shields shall not be used to support fire doors.

(m) Hinges for swinging fire doors, except in wooden stud walls,

shall be riveted or through-bolted to the structural steel frame of

the opening, through-bolted to the wall if of masonry or concrete or

secured by approved inserts in the concrete or built into masonry in

approved manner.

(n) Strap hinges and sliding door hangers shall be secured to

fire doors by through-bolting, riveting or welding. Swinging fire

doors in rabbeted frames, except tin-clad, wood core doors, may be

hung on butts. Other swining fire doors shall have strap hinges.

(o) Sliding fire doors shall have adequate stops for the closed

position. Swinging Class A fire doors shall have surface latches or

unit locks. Class B and Class C doors shall have surface latches,

unit or mortise locks. The latch bolts of unit or mortise locks on

16 RS 22-4
fire doors shall have a throw of three fourths inch. When nounted in

pairs fire doors shall be rabbeted by means of an astragal or otherwise where they come together. One of a pair of swinging fire doors

shall have push bolts at top and bottom with a throw of three fourths

inch and the other shall be held by latch to the first.

(p) Except in detention buildings, fire doors hung in required

exits shall be so fitted with hardware that they can be opened from

inside without use of a key when the building is occupied.

FIRE DOOR CONSTRUCTION

(a) In the construction of fire doors solder shall not be used,

except for filling joints. Sheet metal shall be fastened to wood by

nailing and to metal frame by bolting, riveting or welding.

(b) Class A doors shall not have glass panels. Class B doors may

have glass panels not larger than one hundred square inches in exposed

area nor more than twelve inches in width or height. Class C doors

may have glass panels not larger than two thousand jmd sixteen square

inches in total exposed area, and no single light shall have an exposed

area exceeding twelve hundred and ninety-six square inches. Glass in

fire doors shall be wire glass not less than one quarter inch thick

and shall be set five eighths inch in grooves three quarters of an

inch deep.

(c) Fire doors shall be constructed as follows: —

(1) Tin-clad, three-ply wood core doors shall be constructed

in accordance with the specifications of the National Boar of Fire

Underwriters for such doors in Class A openings, and shall bear the

label of the Underwriters Laboratories to this effect.

(2) Tin-clad, two-ply wood core doors shall be constructed

in accordance with the specifications of the National Board of

Fire Underwriters for such doors in Class B openings and shall

bear the label of the Underwriters Laboratories to this effect.

(3) Hollow metal doors shall have substantial stiles and rails

of heavy pressed steel, reinforced for hinges and other hardware.

Panels shall be of sheet steel filled with asbestos board or other

approved insulating materials. The door shall be assembled by

welding or riveting.

(4) Sheet metal doors shall be constructed with a rolled

steel rigid frame covered both sides with one sixteenth inch

asbestos board ^md twenty-six gage corrugated sheet metal, with

corrugations vertical on one side and horizontal on the other,

bound on the edges with rolled steel or pressed steel shapes.

17 RS 22-4
(5) A steel rolling fire door shall be constructed of

sheet steel interlocking slats, sliding in grooves, counterweighted by springs, the roller and mechanism enclosed in heavy

sheet metal.

(6) A steel plate fire door shall be constructed of not

less than twelve gage steel plate mounted on a rolled steel

frame, assembled by welding or riveting.

(7) A metal clad, paneled fire door shall have a wood core

with stiles and rails not less than one and three fourths inches

thick covered with twenty-six gage sheet steel; panels three

fourths inch thick covered with twenty-six gage sheet steel, set

three fourths inch in grooves; joints of metal lapped and well

nailed.

(d) A door properly bearing the Undervriters ' Label certifying

that it is suitable for the protection of a Class A opening shall

be acceptaUsle as a Class A door.

(«) A door properly bearing the Underwriters* Label certifying

that it is suiteible for the protection of a Class B opening shall

be acceptable as a Class B door, except that metal clad doors wider

than three feet shall not be accepted as Class B doors.

(f) A door properly bearing the Underwriters' Label certifying

that it is suiteible for the protection of a Class C opening shall

be acceptable as a Class C door.

N. FIRE-RES I STIVE SHUTTERS

Shutters required to be fire shutters or fire-resistive shutters shall

be constructed and hung as specified for Class B fire-resistive doors in

sections L and M.

0. FIRE-RZSISTIVE WINDOWS

(a) Windows v^ich are required to be fire windows, fire-resistive

windows, or of fire-resistive construction shall conform to the

requirements of this section.

(b) Fire-resistive windows may be fixed or arranged to open and

close. Fixed fire-resistive windows shall be so secured in the

walls in which they are placed that they may expand in case of fire

without buckling. Movable fire-resistive windows shall be opened or

closed in one of the following manners: —

(1) One or more sashes may slide horizontally in a fireresistive frame.

18 RS 22-4
(2) One or more sashes may slide vertically with counterweights or with two sashes counterbalanced and hung on chains.

If a sash is closed in raised position it shall have a fastening.

(3) A sash may be hinged at top, bottom, or either side.

(4) A sash nay be pivoted at top and bottom or at the sides.

(5) A sash may be arranged to open and close in any other

approved manner, with approved hardweure.

(c) Movable sashes in fire-resistive windows shall be fitted to

fire- resistive frames of the same or similar construction. Both

sashes and frames, and metal mullions between window units, shall

be so fitted in the walls in which they are placed as to be continuous with the fire-resistive material of the wall and so secured that

they may expand in case of fire without buckling.

(d) Glass in fire-resistive windows shall be wire glass not less

than one fourth inch thick and the area of a single light shall not

exceed seven hundred and twenty square inches. Glass shall be set

three eights inch in grooves at least one half inch deep. Glass shall

be secured by glazing angles or moldings screwed to the sash and forming continuous grooves for the glass.

(e) Fire-resistive windows shall be of the following construction: --

(6) Hollow sheet metal sashes and frames fabricated by pressing,

welding, riveting or crimping without the use of solder or other

fusible alloy, except for filling joints, and bearing the label of

the Underwriters' Laboratories.

(7) Rolled steel or pressed steel sashes fabricated by

pressing, welding, riveting or crimping, of a make and style

approved by the conmissioner

.

(8) Any other approved constructions as fire-resistive as

that specified in paragraph (6)

.

(f) Fixed fire-resistive windows of hollow sheet metal construction

shall not exceed seven feet in width nor ten feet in height. Fireresistive windows of hollow sheet metal construction with movable sashes

shall not exceed six feet in width nor ten feet in height.

(g) Fire-resistive windows of rolled steel construction shall not

exceed eighty-four square feet in area nor twelve feet in either height

or width.

(h) Fire-resistive windows and their fastenings shall be capable

of resisting the wind pressure on the wall of the building applied

either on the inside or the outside of the window without exceeding

alloweible stresses.

19 RS22-4
(i) Where fire-resistive windows are required, wooden windows end

plain glass may be substituted provided the openings are protected

by fire-resistive doors or shutters, or, in buildings of approved

occupancy and construction, by an approved system of open sprinklers.

FIRE-RESISTIVE ROOF COVERING

(a) Roof covering allowed under this code shall be clasified as

f ire-retardant or ordinary, according to their resistance to fire

outside, as provided in this section. F ire-retardant roof covering

is the more fire-resistive and may be used on any building. Ordinary

roof covering shall not be used where f ire-retardant roofing is specified. Roof covering less fire-resistive than ordinary roof covering

shall not be used on any building.

(b) Fire-retardant roofing shall be any roof covering meets the

requirements of Class A or Class B roofing under the specifications

of the Underwriters' Laboratories , Inc. The following roof covering

shall be assumed to meet the requirements for fire-retardant roofing:

(1) Built up roofing consisting of successive layers of roofing felt ijnpregnated with asphalt; a final layer of asphalt in which,

while molten, is embedded a continuous layer of roofing gravel or

slag.

(2) Built up roofing consisting of successive layers of roofing felt impregnated with coal tar; a final layer of tar in which,

while molten, is embedded a continuous layer of roofing gravel or

slag

(3) Built up roofing consisting of successive layers of roofing

felt impregnated with asphalt; a final layer of asbestos roofing felt

impregnated with asphalt weighing not less than fourteen pounds per

hundred square feet, or a final layer of asphalt-saturated prepared

roofing coated with granulated slate or other similar material.

(4) Built up roofing consisting of successive layers of roofing

felt impregnated with tar or asphalt and a finish of burned clay

floor tile, stone flagging, cement concrete or other similar material.

(5) Sheet metal with locked and soldered joints not less than

number twenty-six gage in thickness.

(6) Shingles of natural slate.

(7) Shingles of burned clay tile.

20 RS 22-4
(8) Shingles of sheet metal not less than number twenty-six gage

in thickness.

(9) Shingles of asbestos board not less than one-eighth inch

thick.

(10) Shingles of asphalt saturated felt surfaced with granulated

slate or other similar material and carrying the Underwriters Class

"C" label.

(11) Corrugated sheet metal with lapped joints not less than

number twenty-six gage in thickness.

(12) Corrugated asbestos board not less than three-sixteenths

inch thick.

(c) Ordinary roofing shall be any roof covering which meets the requirements of class C roofing under the specifications of the Underwriters'

Laboratories, Inc. The following roof covering shall be assumed to meet

the requirements for ordinary roofing:

(13) Built up roofing consisting of successive layers of roofing

felt impregnated with asphalt, coal tar or other approved material,

not equal in fire-resistance to" a f ire-retardant roofing.

(14) Prepared roofing consisting of felt or fabric impregnated

or coated, or both, with asphalt, tar or other approved material or

shingles of such prepared roofing, not equal in f ire-retardant roofing.

(15) Canvas stretched tightly and coated with paint.

(d) Built-up roofing shall be secured to the roof deck in the following manner:

(1) Over masonry slab. The first layer shall be laid in molten

asphalt or tar mopped on the roof deck, after the deck is properly

primed, or by nailing a layer of building paper to nailing inserts

other than wood placed in the deck.

(2) Over wood decks the built-up roofing shall be secured by

nailing a layer of building paper to the roof deck over which the

prepared roofing is to be laid with the first layer laid in molten

asphalt or tar.

(3) Roofings other than built-up roofings, such as shingles,

slates, tile roll roofing shall be well secured to the deck by

nailing, bolting, wiring, or other approved me*".hods.

21 RS 22-4

ATTACHMENT A

RECOMMENDATION ON CURJIENT SECTIONS

OF MASSACHUSETTS STATE BUILDING CODE

(based on draft attached)

Delete Sections 105.0 and 106.0 entirely and substitute the following:

Section 105.0 Existing Buildings and Structures

105.1 General: The repair, alteration, addition to and change in

use of existing buildings and structures shall comply with

the provisions of Article 22.

Add Section 304.1.3 to Section 310.0 as Section 310.1.1; delete the

remainder of 304.0 entirely.

Delete Sections 405.3 through 405.4.2 entirely.

Delete Sections 417.2.6 and 417.2.7 entirely.

Revise 436.5.1 to read "This section and Article 22 shall apply to all

historic buildings which are not defined as totally preserved buildings".

Delete 436.5.3, 436.5.4, 436.5.6, 436.5.7 and 436.5.8 entirely.

Revise Section 600.1 to read, "600.1 Scope: The provisions of this article

shall control the design, construction and arrangement of building elements

required to provide a reasonably safe means of egress from all buildings and

structures hereafter erected. All existing buildings and all buildi.ngs

hereafter altered to a new occupancy load or manner of use or inherent fire

hazard shall comply with the provisions of Article 22".

Delete Section 604.0 entirely.

23
Attachment A

Page 2

8. Revise Section 706.3 to read " within the limitations prescribed in

Article 22, the structure may be

9. Revise Section 718.67 to read "718.67 Alterations: Structural alteration

may be made

24
Suounary of Reconmcnded Action to be TeJcen on Sections

of

Proposed Mass. State Building Code Referring to Existing Buildings

Delete Revise Remain

105.1 105.0 102.0 405.1 1005.0

105.2 106.0 104.0 405.2 1102.3

105.3 436.0 111.4 417.2.2 1102.4

105.4 600.1 111.41 417.2.3 1103.0

106.1 706.3 116.0 433.1 1200.3

106.2 718.67 117.0 437 .2.1 1200.8

106.3 120.2 505.0 1201.1

106.4 120.3 600.2 1201.2

106.5 121.0 600.3 1305.0

304.0 124.0 605.0 1307.1.1

405.3 125.0 621.0 1307.1.3

405.4 302.0 706.0 1307.2.1

417.2.6 309.0 706.1 1312.0

417.2.7 310.0 706.2 1403.0

604.0 311.0 706.4 1404 .

0

312.0 802.3 1805.0

313.0 803.0 2001.3

403.0 804.0 2002.0

405.0 1002.1

25
Draft of Sections of the Mass. State Building Code

to be Deleted or Revised

SZCTICii 105.0 OLlUICE D( EXISTIKC USE

105.1 CONTDnL^IION OF E-XISTCiC USZ: The legal use and occupancy

of any structure existing on January 1, 1975, or for which->lt had

been heretofore approved, cay be continued vithout change, except

ae uy be specifically covered in ths Basic Code or as cay be

deaaad necessary by Che building official for the generaJ. safety

and uelfare of the occupants and the public.

105.2 CEAKCZ m USE AJTD CCCUPAWCT; It shall be unlawful to make

2ny change in the use occupancy of any structure or parts thereof xrLthout the building official having issued a certificate of

uje and occupancy indicating that such scructurs. cooplies vithr

thi provisions of the Easlc Coda for the proposed new use or occupa::cy ar.d thaC such change does not result in any greater hazard to

P'^blic infecy or welfare.

105.3 PA-RI CEA^ICE m USE: If a portion of the building is changed

in occnpancy or to a nev use group aad that portion is separated

frcn the re=ainder of the building with the required vertical and

horizsntal fire division conplying vrlth the fire grading in table

9-1, then the cocstrucCion involved in the change shall be cade to

cooiora to the requireisents of the Basic Code for the nev use and

occupancy and the e.xlsting portion shall be cade to cocply vlch

the e;xltvay requireaaats of the Basic Code.

105.4 R£EST/^LISr>GMT OF A PRIOR USE: After an approved change

of uss has baen cade to a building or parts thereof, the reestab—

lishnent of a prior use that is not legal to a new building or

parts thereof of tha sase type of construction, is prohibited unless

all the applicable provisions of tha Basic Code have been oet.

SECTION 106.0 ALTERATIOMS & REPAIRS

E:icept as provided in this section, existing buUdlnss or structures when altered or repaired as herein specified shall ba cade

to confom to the full requirecents of the Basic Code for new

buildings:

106.1 ALTZ?-\TICMS EXCEEDING FIFTY PE"'.CDrr: If alterations or

repairs are cade within any period of twelve (12) conths, costing

in s::ces3 of fifty (50) percant of the physical value of tha building: or
106.2 DAMAC2S EXCIEDDIC FirTY ?ISLCI^: t Che baildiag is daaaged by

£ir« or any oth«r caus* co an •xtenc in excess of fifty <50) percent of

Che physical value of ehe building before che da=age vas incurred.

106.3 ALTDUTION UN'DEX TZTTL PEXCZirr: If che cost of a^caracioas or

repairs described herein is becueen cwency-fiva (25) and fifty (50)

percent of ehe physical value of the building, the building official

shall decersine co what degree the portions so altered or repaired shall

be Bade to confora to the requixeaents for new buildings:

106.4 ALT£3ATI0H UNDESL TWSm-mi PESCOT: If t-he cost of alterations

or repairs described herein is Cvanty-fivm (25) percent or less of the

physical value of the building, the building official shall perait the

restoration of the building to its condition previous to dasage or

decerioration vith the saae kind of caterials as those of vhich the

building vas construe tad; provided that such conscr'action does noc

endanger the general safety and public velfare and conpliss with the

provisions of article 9 in respect to existing roofs.

105.5 PHTSICAL VALUE: In applying the provisions of this section, the

physical value of the building, at the option of the ovr.er, shall be

bAsed on che assessed value of the building as recorded in the assessor's

c'ffce of the nunicipality or on the basis of the current replacesest

cose of th'xbuilding less physical decerioration, provided that satisfactory

evidence of the. current replacement cost less physical deterioration is

subaitted to the building official for his approval.

SECTION 304.0 DISTINC BUJLOINCS

304.1 Alteration

304.1.1 Limitatioas: These provisions shall not be deeded to prohibit

alterations within the limitations of Section 106.0, provided an unlawful

chajige of use is not involved.

304.1^ Minor changes: Changes, alterations or repairs to the interior

of a buiJdine and to the front facing a street or other public space may

be permitted, provided such changes, in the opinion of the buiJding oS*

cial, do not increase the size or the fire hazard of the building or en- danger the public safety, and axe not specifically prohibited by Lbis code.

304.1.3 Exisdng pro)«cdons: A change or enlargement shall not be

made to an existing part of a buiJding now projecting beyond the street

lot line or building line where such is established by law, e.tcept in conformity- to the provisions of Section 310.0 governing new construction.

304.2 Increase in height and area: It shall be unlawful to increase the

height or area of an existing building or structure, unless it is of a type

of construction permitted for new buildings of the increased height and

area, and of a use group within the fire limit in which it is locsted and as re^jlared bv Table 305.

27
417.2.6 Existing buildixigs: Nothing herein contained shall prohibit

the alteration of a buildLsg heretofore occupied as a place 0/ public

assembly for such continued use provided tne occupancy load is not

increased and seats, aisles, passageways, balconies, stages, appurtenant

rooms and all special permanent equipment comply with the requirements of this article.

417.2.7 New buildings: A building not heretofore occupied as a place

of public a^iembly shall not hereafter be altered to be so occupied unless it is made to comply with all the provisioiu of this article.

436.5.1 APPLICABILITY': This Section shall apply Co all HISTORIC BUILDINGS

which are NOT defined as TOTALLY PRISERVED BUILDINGS.

436.5.3 REPAIRS AMS MAINTDIANCI; The owner of a partially preserved building nay perforai any repairs and maintenance without increased conforTiity

to the Basic Code, as defined in Section 102, and provided chat a building perr.it has been issued and that no change of Use and Occupancy occurs.

436.5.4 NE;>7 SYSTEMS: When an entirely new electrical or rscchanical systeri and/or equipcent is installed in a partially preserved building, they

shall be subject to the provisions of Section 103.0 and Sections 1102 0

22010*, 2201.Jj and 2201.^4.

'

436.5.6 CHANGE IN OCCUPANCY: Before any chinje in the use or occupancy

cf any partially preserved building or parts thereof, the building official shall inspect the building and shall determine whether Che proposed

new use and occupancy constitutes lesser, equal, or greater hazard in

accordance with Table 2-6. Any increase in the proposed density or

occupancy not in conformance with Sections 605 and 706 and cot having

a change in use shall also constitute a greater hazard.

.-.ny change in use or occupancy shall be evaluated relative co the last

kncvn legal occupancy of the building. After the building official deterr.ir.es chat the building conforms to Section he shall issue

a Certificate of Use and Occupancy,

436.5.7 LESSER ANTD EQU.\L HAZARD: If a partially preserved building,

after a change in use or occupancy, will be in a lower or equal Hazard

Group (Table 2-6), no increase in compliance to the Basic Code will be

required provided that it conforms to Sections 4Q4, 2!^* 506 . 6Q2. 62i, , 524, IS1S S, 10^6. The renoval of non-original safety features introduced

into partially preserved buildings in order co meet more stringent code

requiren^ents for prior occupancies may be permicced if lesser hazard

exists and if such features are not required for the proposed use or occupancy.

436.5.8 CRL^TZR HAZARD: If a partially preserved building, afcer a

charge in use or occupancy, will be in a higher hazard group (Table

2-6), :ocal compliance to the Basic Code shall be required, for that I use group.

j 28
SECTION 31 OJ PUMtSSlBU STREH PROJECTIONS

310.1 General: Subject to such provisions as may be otherwise prescribed by law or ordinaace, or by rule of the municipal authorities having jurisdiction over streets, highways, and public spaces, the following

projections, as described in Sections 310.2 through 310.11.1, shall be

^rmitted beyond the street lot line or the building line, as the case may

310.2 Cornices and caves: Main cornices or roof eaves located at least

twelve (12) feet above the curb level shall project not more than three (3)

feet.

405.3 Places of assembly

405.3.1 Change of use: An existing building or structure or part thereof shall not be altered or converted into a place of assembly unless it complies with all provisions of this code applicable to places of public

assemblv hereafter erected.

405.3.2 Existing us« altered: When an existing building or structure

heretofore used as a place of public assembly is altered and the cost of

such alteration is more than fifr^ (50) per cent of the physical value of the

building as defined in Section 106 8, all provisions of this code relating

to new places of public assemblv shall be complied with. When the cost

of such alteration is less than Bkv (50) per cent of the physical value of

the building, such alterations shall comply as nearly as is practicable with

the provisions of this code which govern the arrangement and construction of seats, aisles, passageways, stage and appurtenant rooms, firefighting and extinguishing equipment and the adequacy of means of

egress.

405.3.3 Increase in occupancy load: \Vhenever the occupancy load of an existing place of public assembly is increased beyond the approved

capacit)' of its exitvvays, the building or part thereof shall be made to

comply with the requirements for a new building hereafter erected for

such public assembly use.

405.4 SNvimming pools

405.4.1 Change of use: An existing pool used for swimming or bathing

or accessory equipment or part thereof shall not be altered or converted

for any other use unless it complies with all provisions of this code

applicable to the use intended.

405.4.2 Continuation of e.usting uset E.xisting swimming pools may b«*

continued without change, provided the safety requirements of Section

423 5 are observ'ed where required by the building official.

29
600.1 SCOPE: The provisions of this Article shall control the desipi.

construction and arrangemeac of building tlenents reiuired to provide a reasonably safe means of egress from all buildings hereafter erected,

and froQ all buildings htreaftar altered to a new occupancy load, or

r.anner of use, or inherent fire hazard.

SECTION 804.0 CCISTlNe BUILDINGS

604.1 Owner responsibility: The owner or lessee of every existing building and stTucnire shall be responsible for the safety of all persons in, or

occupying, such premises with respect to the adequacy of means of egress

therefrom.

6042 Vniilt metna of egress

604.2.1 Inadequate exitways: In any e.Tisting buildi::g or structure, not

provided with e«tway facilities as herein prescribed for new buildings and

in which the exifways are deemed inadequate for safety by the building

oficiai such additional provision shall be made for safe means of egress as he shall order.

604.2J! Appeal from cxitway order: Within seven (7) days after the

service of the exiP-vay order of the building official the owner may file a

written appeal therefrom, and the building official shall appoint a board of

survey as required Ln Section 125.0 to make a final determinadon.

706.3 EXISTING LIVE LOAD: When an existing buildizg heretofore approved

is altered or repaired within the linitations prescribed in sections

1Q6.3 or 106.4, the structure may be designed fcr the loads and stresses

applicable at the tine of erection, provided tha public safety is not

endangered thereby.

713.67 MD^'OR ALTE^L^ITONS: Minor struccural alterations may be caadc

in existing buildings and other structures, but the reslstajice to

lateral forces shall be not less than that before such alterations

vere made, unless the building as altered meets the requirements

of this section of the Code.
NBS-114A (REV. »-Ta)

U.S. DEPT. OF COMM.

BIBLtOGRAPHIC DATA

J" SHEET

1. PUBLICATION OR REPORT NO. NBS SP-549

4. TITLE AND SUBTITLE

Proceedings of the National Conference on Regulatory

Aspects of Building Rehabilitation

5. Publication Date August 1979

7. AUTHOR(S)

Sandra A. Berry, Editor

8. Performing Organ. Report No.

9. PERFORMING ORGANIZATION NAME AND ADDRESS

NATIONAL BUREAU OF STANDARDS

DEPARTMENT OF COMMERCE

WASHINGTON, DC 20234

l«.-PioJact/T8sk/Wiirfc Unit No.

11. Contract/Grant No.

12. SPONSORING ORGANIZATION NAME AND COMPLETE ADDRESS (Street, city, state, ziP)

National Bureau of Standards

Department of Commerce

Washington, D.C. 20234

13, Type of Report & Period Covered

Final 1979

15. SUPPLEMENTARY NOTES

Library of Congress Catalog Card Number: 79-600095

I I Document describes a computer program; SF-185, PIPS Software Summary, is attached.

16. ABSTRACT (A 200'word or teaa factual eutxunary of moat significant information. If document includes a significant bibliography or

literature survey, mention it here.)

This document contains the edited Proceedings of the National Conference on

Regulatory Aspects of Building Rehabilitation held October 30, 1978, at the National

Bureau of Standards.

It contains a total of 18 presented papers, all of which address the subject

of rehabilitation—currently a critical issue in the Nation's effort to revitalize

its cities and house its citizens.

Public sector, as well as private sector programs and experiences toward

achieving this goal are covei'ed in one general and three technical sessions.

17. KEY WORDS (six to twelve entries; alphabetical order; capitalize only the first letter of the first key word unleaa a proper name;

separated by semicolons)

Building; code administration; codes; evaluation; existing buildings; performance

standard.

18. AVAILABILITY EUnlimited 19. SECURITY CLASS

(THIS REPORT)

21. NO. OF

PRINTED PAGES

1 1 For Official Distribution. Do Not Release to NTIS

UNCLASSIFIED

220

Pn Order From Sup. of Doc.^^ U.S. Government Printing Office, Washington, DC

20402, SD Stock No. SN 003-003-02107-6

20. SECURITY CLASS

(THIS PAGE)

22. Price

1 1 Order From National Technical Information Service (NTIS), Springfield,

VA. 22161 UNCLASSIFIED

$5. 50

USCOMM-DC

•tr us. GOVERNMENT PRINTING OFFICE : 1979 O—298-595

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BIBLIOGRAPHIC SUBSCRIPTION SERVICES

The foUowiog current-awareness and literature-survey bibli- ographies are issued periodically by the Bureau:

Cryogenic Data Center Current Awareness Service. A litera- ture survey issued biweekly. Annual subscription: Domestic, $25.00; Foreign, $30.00.

Liquefied Natural Gas. A literature survey issued quarterly.

Annual subscription: $20.00.

Supercondncfing Devices and Materials. A literature survey

issued quarterly. Annual subscription: $30.00. Send subscription orders and remittances for the preceding bibliographic

services to National Bureau of Standards, Cryogenic Data

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