Up to Code

What K-12 Administrators Need to Know About the Building Code Process

09/28/2018
FACILITIES
By Deidre “Dee” Leclair, AIA
 

In what has become a standard three-year code cycle at a national level, the International Code Council (ICC) and its supporting committees revise and update the International Codes and standards to evolve with industry trends in design, manufacturing and safety practices.  Every three to six years, the time comes for all 50 states to review the new code changes provided by the ICC.

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The process for code adoption and implementation affecting K-12 schools can become confusing and often presents its own unique set of challenges, especially when dealing with renovations, which is usually the case with K-12 schools. 

Every state has the option to adopt or amend new codes, but as new construction materials become available and standards to mitigate risk are reevaluated and affect the way we design and build schools, it is imperative for school administrators and design and construction professionals working in the K-12 school arena to understand how code changes impact their schools.

The process for code adoption and implementation affecting K-12 schools can become confusing and often presents its own unique set of challenges, especially when dealing with renovations, which is usually the case with K-12 schools. 

Understanding the Various Types of Codes

There are several codes often discussed and reviewed when working on K-12 projects, and it is important to be knowledgeable of each before submitting a project for permitting.

The International Building Code (IBC) is intended to provide minimum requirements for new construction and repair and alternative approaches for renovations to existing buildings.  Additionally, it determines aspects like building occupancy type, construction types, maximum heights and square footage, fire-rated construction, wind provisions and occupancy numbers for special areas like gymnasiums and auditoriums.

The International Mechanical Code (IMC) is a convention concentrating on the safety of heating, ventilation, and air conditioning systems. Simply put, it outlines how HVAC systems, appliances and appliance venting should be installed in school buildings.

The International Fuel Gas Code (IFGC) regulates the addition of any fuel-fired appliances such as gas-fired or oil-fired furnaces, water heaters and gas stoves. This code determines and effects the way gas piping and systems are installed in schools, especially kitchens and the gas piping running to roof top units.

The Americans with Disabilities Act Code (ADA) outlines the inclusion of accessible design for handicapped and disabled students and teachers. This includes handicap parking spots, wheelchair accessible-tables, door vision panels and automatic doors in schools.

The International Fire Code (IFC) outlines ideas surrounding where fire detectors and safety hydrants should be placed throughout the school. From 2011-2015, fires on educational properties accounted for one percent of all reported fires and resulted in one death, 70 injuries and $70 million in direct property damage.

The International Plumbing Codes (IPC) outlines plumbing regulations, including fixture installations and minimum plumbing fixture (i.e. water closets, sinks, drinking fountains) counts for school buildings. This is especially important as more schools begin to implement water conservation programs, including installing low-flow and no-flow fixtures.

The International Energy Conservation Code (IECC) establishes the minimum design and construction requirements for energy consumption – the second-highest operational expense to schools each year, after salaries.

The National Electric Code (NEC) is published by the National Fire Protection Association (NFPA) and deals with the electricity of the building, including the placement of all electrical outlets and panelboards as well as the voltage allowed in places such as classrooms, cafeterias and football stadiums.

NFPA 101 Life Safety Code regulates emergency exits, life safety provisions, maximum occupancy counts and exit signage. This code is unique from most codes as it applies to all existing structures as well as new structures. In states that enforce the Life Safety Code, it is heavily used by architects and designers during the design stage of K-12 schools when trying to determine the egress of the building. Since this code is a valuable source when determining liability in accidents, it is also used by insurance companies to evaluate risks and set rates.

The International Swimming Pool and Spa Code (ISPSC), which regulates and outlines the addition of swimming pools in K-12 schools. This code outlines the entire process from the design and construction of the swimming pool to repair and maintenance.

Navigating the Code Approval Process

ICC’s multiyear code review process tends to incorporate updates to almost every single code it publishes.  In most states, there is a process that allows industry stakeholders, like contractors, architects, engineers, manufacturers, trade associations and facility managers, to amend a code that may negatively impact a single building type, such as schools.  In some cases, if the code language is unclear, or could pose a safety concern, it might also be amended.

For example, if a company manufactures a new device that might be prohibited or limited by the code, that company has the right to propose changes and testify at a hearing to have changes in the code approved. Many companies will attend these public hearings in order to advocate for their products and they may even testify against a proposed code change. Design professionals also might testify for a code change because the language is confusing and might lead to problems during future renovations or construction.

States adopt a list of codes that are typically considered to be a minimum State Code. The code adoption process can be different in each state. Some states use the ICC codes as a base to create their own versions and incorporate their state amendments to each code book that is then also published by ICC.  Some states may publish a separate document that amends the ICC codes.  Since these amendments could impact school design and renovations, it is important to be familiar with them and what state agency may oversee the code adoption process.

Some local jurisdictions may adopt local ordinances that are stricter than the state minimum.  A good example of this would be the cities of Kennesaw and St. Marys in Georgia.  They have adopted the state’s optional Disaster Resilient Construction Appendices as mandatory for renovations and new construction.  This appendix requires all new schools and some renovations to add storm shelters for students and staff.  This code provision was modeled after Alabama’s state law requiring storm shelters in new schools.

The applicable codes required for each building are determined by the timeframe in which the permits for that project are approved. For example, if permits to renovate a school were approved before a new edition of the code goes into effect, that project would not be required to be revised to incorporate any new code changes.

Changes in codes are communicated in a chain-like order. First, each division of the local government must be notified of the new code regulations and changes. This is often shared via a memo or posted on the state government website. After that, the agency responsible for building code adoptions distributes a memo or letter to the superintendents of all the schools throughout the state that outlines which codes have been adopted.

Design professionals and facility managers can readily find training sessions, seminars, online webinars and conferences to learn first-hand what these new codes and regulations mean for the industry and how they will change or alter various projects. 

New Codes, New Challenges

Adopting new codes always comes with challenges. Most often, these challenges are caused by lack of communication between administrators and local jurisdictions. The best thing an administrator can do before beginning the construction process is to communicate with all the parties involved. Contractors and industry professionals will often call and make sure they are aware and well-informed of any new code changes that could affect pending permits for new constructions or renovations.

The design team will then begin to look at the new codes to ensure they plan and design each building up to code. These processes take a large amount of time and local jurisdictions will often have the final interpretation. The best way to avoid confusion and ensure the timing of your project stays on track is to regularly communicate with the local building authority during the design process to make sure your project meets code before you start moving dirt.

Renovations present the largest set of challenges when adopting new codes, as there are many variables when dealing with an existing building and its systems.  The approach is not always straight forward since no code can predict every scenario.  Additionally, the codes for renovations have more area for interpretation, especially on a local level. Depending on the extent of the renovation, a good rule of thumb is the 50 percent rule, meaning that if the renovation consists of 50 percent of the project’s cost or construction or changes to the building systems, then new code regulations may need to be applied.

Renovations can be tricky depending on how much needs to be done. For example, the design team might not be adding sprinklers to its renovation plan, but an official might tell the design team it is impacting enough of the building that a sprinkler system must be included. Although this seems like a minor addition, sometimes changing a few smaller items can add up quickly and put the project over budget.

Code Communication is Key

Provisions to new codes can also increase overall costs, especially if the official decides to make a design team bring the renovation up to current code for all the systems. This is when communication and great relationships with local building and fire officials are beneficial.

By hiring experienced team members and educating themselves, administrators can remove most of the challenges associated with the changing codes and regulations and implement a seamless process for designing and building in the ever-changing world of K-12 schools.

As you can see, the process outlining, adopting and implementing codes can be complex and time-consuming. Educating oneself and keeping up with the various code changes will prevent future challenges. Learn more about this year’s code additions by visiting ICC’s official website at https://www.iccsafe.org/. To see the ICC codes adopted in each state and links to key contacts within those states visit  As you can see, the process outlining, adopting and implementing codes can be complex and time-consuming. Educating oneself and keeping up with the various code changes will prevent future challenges. Learn more about this year’s code additions by visiting ICC’s official website at https://www.iccsafe.org/. To see the ICC codes adopted in each state and links to key contacts within those states visit  https://codes.iccsafe.org/public/.

Deidre “Dee” Leclair, AIA, is a senior architect at Stevens & Wilkinson, a full-service architecture, engineering and interior design firm with offices in Atlanta and Columbia, South Carolina.
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Issue 20.2 | Fall 2018

          Arkansas State University