Appeal 15725

OSSC 2014 section 505.2.1 Area Limitations (mezzanines)

The aggregate area of a mezzanine or mezzanines within a room shall be not greater than one-third of the floor area of that room or space in which they are located. The enclosed portion of a room shall not be included in a determination of the floor area of the room in which the mezzanine is located. In determining the allowable mezzanine area, the area of the mezzanine shall not be included in the floor area of the room.

Open walls above 8’ and fast detection system throughout first floor room with the mezzanine and above/below mezzanine, the detection system will be tied to full building alarm system. (standard smoke detectors could cause false alarms due to drive through, attached are the cut sheets for the proposed type of detectors, The floor-plans on R0.0 designate the proposed area of installation for each type)

Reason for appeal: code section above does not define “enclosed” portion of a room that shall not be included in the determination of the floor area nor does the code define how “open” is open as it relates to partitions in the “room” containing the mezzanine. The IBC commentary discusses limiting the mezzanine size “a mezzanine is restricted to a maximum of one-third of the area of the room with which it shares a common atmosphere”. Sharing a common atmosphere begins to describe the intent of the code to define what is a room with a mezzanine.

We have excluded all rooms on the first floor with full height walls that do not share same atmosphere and all storage units under the mezzanine that have limited shared atmosphere. Below is our proposal to address the 19’7” high partitions remaining in the room that are partially covered by 8’ metal panels and roll up doors with support frames in the “room” to be used to size the mezzanine and the hallway under the mezzanine. The storage areas included in the room are open to structure above 8’0” (11’7” open) and have no ceiling other than 2x2 wire mesh at 10’0” to provide security, we believe these areas share the same atmosphere.

Proposed design uses the non-crosshatched area on the ground floor as a room sharing the same atmosphere as the mezzanine to determine the allowable size for the mezzanine. See attached plan detail 1/R0.0 the non-cross hatched area includes areas with 19’7” ceiling and open hallways under the mezzanine (open mesh above 7’2”’ at 7’ doors). The cross hatched areas are not included in calculations to size the mezzanine. Attached plan also includes wall sections of storage area partitions in the 19’7” area, see detail 4/R0.0. The 19’7” high partitions have metal panels up 8’ and open 2x2 grid above 8’ to 10’, 10’ to 19’7” the partitions are open studs, and 2x2 open metal grid as security across the ceiling at 10’0””. The 8’ metal panels provide privacy and security for the individual storage spaces, the 2x2 grid provides security and openness for shared atmosphere.

As noted above the code does not define how “open” partitions need to be to be considered sharing the same atmosphere except when discussing openness of the mezzanine to the room below and sets the height at guardrail height 42”. We believe the code intent of this provision does not apply to partitions on the first floor. The openness of the mezzanine to the room below was intended to provide early warning of a fire in the room below as mezzanines are allowed to exit through that area. The openness of the mezzanine goes away and is allowed to be enclosed with the addition of an exit path to the exterior. We have proposed two enclosed exits to the exterior. We believe the openness of the 19’7” partitions and the 2x2 mesh above the doorways in the halls under the mezzanine meet the intent of sharing the same atmosphere and to further enhance the early warning for exiting from the facility we are proposing to add fast detection sensors in the open area on the first floor and in all areas above and below the mezzanine to offset any concern with the use of 8’ metal panels on the first floor. The fast detection sensors will be tied to the full building alarm and emergency voice/alarm communication system proposed per exception 505.2.1 (2) for a fully sprinklered Type II building, allowing mezzanine increase to 50% of the room containing the mezzanine.

The code is silent on how open does a partition need to be for an area to be considered the same atmosphere. Code section “505.2.3 Openness” does reference walls not more than 42” height, we believe this refers to how open the mezzanine is to the room and not how open partitions on the first floor need to be to be considered sharing the same atmosphere.

The proposed partitions, 19’7” high with 8’ metal panels and 11’7” open construction we believe provides the “shared atmosphere” discussed in the IBC commentary for this code section. The addition of fast detection sensors noted above we believe exceeds the requirements of the code and enhances life safety for the facility.

Northwest Self Storage provides privacy and security for their customers through individual storage areas that are not readily visible to other users, partitions are constructed with 8’ metal panels and 2x2 wire mesh above the metal panels (or in some cases spaced hat channels to limit access and provide security), and at tall units 2x2 open metal grid at 10’ across the ceiling is provided. The metal panels and 2x2 wire mesh maintain security and sense of privacy without limiting or interfering with the mechanical ventilation of the shared atmosphere, sprinkler, or lighting systems. This business model is highly desired by NWSS customers. We believe the proposed alternate method described above more than meets the code intent and provides a safe, private and secure environment for NWSS customers.

OSSC 2014 section 2902.3.2 Location of toilet Facilities in occupancies other than malls.

In occupancies other than covered and open mall buildings, the required public and employee toilet facilities shall be located not more than one story above or below the space required to be provided with toilet facilities, and the path of travel to such facilities shall not exceed a distance of 500 feet.

The proposed design would provide all of the required toilet facilities for the entire (3) story building on the 1st floor, more than one story above or below the space required to be provided.

At completion, this self-storage facility will have 534 units. Based on client data, a storage client will
visit their storage unit on average once every 1.3 years. If you look at daily activity, this equates to 1.9 visits per day. I acknowledge the actual load will vary, but want to provide actual usage numbers.

It is possible to add additional toilets to the third level or all toilets on the 2nd level to meet the every other floor required by Chapter 29. Based on client experience, this would not serve the users well, and ask that you consider the following. The users of a self-storage facility are not stagnantly occupying the space that is being used for storage typically to the OSSC definition of occupancy. The actual users of a self storage facility are moving personal items from the loading area to their storage unit. There is limited congregation by the users of a self-storage facility because the space is not designed for occupancy, but for circulation and storage of personal items. Under the exceptions for 2902.3.2.1, in group B (other than restaurants and dining facilities), F, H, M, and S occupancies, toilet facilities may be located in an adjacent building on the same property. The path of travel to such facilities shall not exceed a distance of 300 feet and be on an accessible route complying with chapter 11. This is an exception to the requirements for 2902.3.2. The travel distance within the building does not exceed the 300-foot travel distance. The exception allows plumbing fixtures in another building without consideration of the number of stories in the first building. The only consideration is the travel distance requirement of 300 feet. The travel distance within the proposed self-storage building does not exceed the 300-foot travel distance.