By Warren Burns
Telgian Regional Practice Leader – Fire Protection Engineering
Code compliance, by strict definition, is compliance with a written, adopted or required set of rules that have been set into a code format. This article will focus on building and fire codes. The International Code Council (ICC) family of codes is the predominantly recognized code set in this industry, and are considered prescriptive codes, in that they prescribe a defined approach to compliance. Prescriptive codes can also be thought of as reactive codes, in that a code-writing body will review existing codes, apply known failures or discrepancies and shortcomings, and revise the code on a regular basis. (Every three years in the case of the ICC) As such, the codes are amended to reflect responses to existing circumstances known to the code-writing body at the time of the amendments. They react to issues already known.
Codes provide the what, when and where of compliance, and to some extent the how. Who and why are determined by local adopting ordinances. The explicit how usually comes in the form of nationally-recognized standards, in the case of the International Fire Code (IFC) that is often the National Fire Protection Association (NFPA). The long and the short of this is, if you need to provide fire protection, there is almost certainly a very-strictly prescribed method (and material) with which to do so.
But what if that method (or material) is unreasonable expensive, or in conflict with your intended use of the protected property? First, let’s look at the intent of the IFC. (Section 101.3) “The purpose of this code is to establish the minimum requirements consistent with nationally recognized good practice for providing reasonable level of life safety and property protection…” (Emphasis added) “Minimum” and “reasonable” are somewhat ambiguous, but do allow for the fact that the code writers are recognizing that there is no one answer to fit every possible scenario. Later in Chapter 1, section 104.9 specifically, resides the Alternate Methods and Materials clause. It states “The provisions of this code are not intended to prevent the installation of any material or to prohibit any method of construction not specifically prescribed by this code, provided that any such alternative has been approved.” It goes on to state who can approve and offers research reports and testing as two methods of determining the suitability of an alternative method or material.
This opens up the possibility to view the code as a performance-based code, where specific performance objectives are set and the proponent is tasked with proving their approach meets that objective. By offering section 104.9 the code is allowing that alternatives that meet the intent do exist, and that a proponent can provide those alternatives, in an approved format, and receive consideration of meeting the performance requirements of the code (see intent) to provide at least a reasonable level of life safety and property protection.
The Engineering and Consulting staff here at Telgian fully understands the requirements of the prescriptive code(s) and, in most cases, are party to the code-writing body that develops and amends them. But we also fully understand and appreciate the latitude of section 104.9, and routinely present acceptable alternatives to the prescriptive language to assist our clients in providing equivalent or greater levels of fire and life safety protection for their properties. Fire and Life Safety are non-negotiable. How we get there can be.
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