STATE BUILDING CODE INTERPRETATION NO. 96-01
 
CODE: 1991 Washington State Uniform Building Code (1991 UBC) and 
1994 Washington State Uniform Building Code (1994 UBC)
SECTION:  Section 3802 (e) 3 in the 1991 UBC and 
Section 904.2.4.1 in the 1994 UBC
QUESTIONS:  1. When the use of a building changes from Group E-2 to Group E-1 Occupancy Classification, does the change in use create a "newly constructed building" as described in 1991 UBC Section 3802 (e) 3 (1994 UBC Section 904.2.4.1)?

2. Since 1991 UBC Section 3802 (e) 3 is more specific (applying only to Group E, Division 1) does the 1500 sq ft basement sprinkler exemption of Section 3802 (e) 1 apply only to Group E, Divisions 2 and 3?

3. The 1994 UBC does not include the 1500 sq ft basement sprinkler exemption for Group E Occupancies (1994 UBC Section 904.2.4.2). When applying the 1994 UBC would a 1500 sq ft or smaller basement need to be sprinklered where there is a change in use from Group E-2 to Group E-1 Occupancy?

ANSWERS:  1. No. A change in use does not create a "newly constructed building" as described in 1991 UBC Section 3802 (e) 3 (1994 UBC Section 904.2.4.1). (See also State Building Code Interpretation No. 95-15.)

2. No. The application of 1991 UBC Section 3802 (e) 3 is specifically for "newly constructed buildings" as described in that section, whereas Section 3802 (e) 1 applies to new construction as well as to existing buildings which have a change in use. (See Section 502 which contains change in use requirements.)

For interpretation of 1991 UBC Sections 502 and 3802 (e) 1, please contact the International Conference of Building Officials, publishers of those code sections.

3. The following comments are advisory only:

The requirements of the state amendments to 1994 UBC Section 904.2.4.1 do not eliminate the other code requirements which must be met when a building has a change in use from Group E-2 to Group E-1 Occupancy. Therefore, it appears that while an existing building which has a change in use may not be required to be fully sprinklered per Section 904.2.4.1, Section 904.2.4.2, which requires basements of any size in Group E Occupancies to be sprinklered, does apply when there is a change in use. (For Change in Use requirements please see Section 3405.)

For interpretation of 1994 UBC Sections 904.2.4.2 and 3405 please contact the International Conference of Building Officials, publishers of those code sections.

SUPERSEDES: None 
REQUESTED BY:  City of Othello