Codes and standards are a basis of building and facility design. Even with the best of intentions, sometimes new code requirements are at odds with a building’s usability while offering no clear benefit. My job, as the SSA’s codes and standards consultant, is to ensure that our industry’s interests are represented when these national model codes and standards are under development.
In the past several years while working with the SSA, we’ve had a significant impact on the codes that affect our members. The 2024 International Mechanical Code (IMC) confirms that the occupiable floor area in warehouses does not include the floor area of self storage units. By clarifying that the storage units are not part of the occupiable floor area, the minimum fresh air intake rates can be properly calculated and consistently enforced. This is significant because the greater the fresh air intake, the higher the HVAC equipment costs and energy costs to run the equipment. Furthermore, oversizing equipment limits an air conditioner’s ability to control humidity.
We were also able secure an exception in the 2024 International Building Code (IBC) regarding individual unit lighting. Many jurisdictions already do not require lighting inside of individual units because they are not considered occupiable and there is a safety concern of tenants using electricity for personal use and unregulated activities. However, some code officials disagree and require lighting inside of individual units. The lighting exception covers storage units 400 ft² (37.16m²) or less in area that are accessed directly from the exterior of the building.
During the prior IBC cycle for the 2021 code, we were successful in adding an exception to the more stringent sprinkler requirements that were added into the building code in 2012. With the newly added exception, traditional single-story facilities that have exterior access to the storage units can use fire barriers every 12,000 square feet as an alternative to sprinklers or firewalls every 2,500 square feet.
We were also able to secure an additional story allowance in sprinklered, unprotected steel buildings, known in the building code as Type IIB construction. The ability to have a fourth floor in these buildings has made the difference in some cases of the project being feasible from a construction cost standpoint or not.
Another big win for our members is an exception we were able to secure to maximum restroom travel distances and frequency. Without the exception, restrooms are required on at least every other floor and within 500 feet of any location within the building. The exception provides the code official with the express discretion to reduce the number of restrooms required.
Even though the international codes are developed years before being adopted and enforced by most states, many members have been successfully implementing these changes early in their construction projects. Because codes are only updated on three-year cycles, designs that are shown to be equivalent in safety can be used as an alternative method now. It is reasonable for building officials to deem future codified code language as equivalent. To that end, I have prepared memorandums that are available in the Legal Resource Center of the SSA’s website to assist with current projects prior to formal adoption.
Even when we’re not playing offense, we’ve been able to help mitigate damages from code changes that could otherwise have had an adverse effect. The IBC has a requirement for pull stations in storage facilities. By working with the proponents of the proposal in an earlier code cycle, we were able to add a backstop at three stories or greater and put in an explicit statement that visible notification appliances are not required within storage units. By monitoring NFPA 101, the Life Safety Code, which is used in a handful of states on the east coast, we were able to ensure a proposal was defeated that would have retroactively required sprinklers in existing high-rise storage occupancies.
Work on the next code cycle begins next year, and we encourage members to work with us so that we know what code issues are being faced in the field. We also work with members to help resolve individual code issues, which can help inform our strategy for national work.