Code Compliance

I was recently asked by one of our school customers to check “the code” and help determine the occupancy load of a large room. He provided the quantity and size of the exit doors as data to help me answer his question.

Sounds like a simple enough question, especially from someone who is not familiar with “the code.” But if you are familiar with building codes and life safety codes, you likely already know that “simple question” and “the code” are incompatible terms. Before you begin to figure out the answer to the code question, you have to start with answering “which code?” And before you can answer that question, you might have to answer, “which municipality?” Our typical customer is located in a city, within a county, within a state, and each of these municipalities claim some level of authority having jurisdiction (AHJ). The rule of thumb for AHJs is that the subordinate municipality can be stricter with codes, but not more lenient. But if the different AHJs have adopted different codes (which is not uncommon in my neck of the woods), you still have to satisfy them all.

If you prefer to do the research yourself, which is a fairly enlightening process, depending upon the “code” that is adopted by your AHJ, be prepared to spend some money. It is common for laws to be accessible for free to the public, but if a municipality adopts a standardized code into law, that code is available to be purchased. The state of Tennessee has adopted standardized codes from both the NFPA (Life Safety Code) and the ICC (Fire Code, Building Code, Energy Code and Residential Code). Any one of these code books can be readily purchased online for about $75-$100. But each of these codes also include, by reference, multiple other code and standard books. I recently heard a fire marshal in a presentation to facility managers declare that their office estimated the cost of all of the code books that have been legally adopted in their municipality at $40,000-$50,000. This is because it is so common for the codes to reference so many other standards. The ICC International Fire Code alone references nearly 200 other standards from about 20 different organizations (e.g., ASME, ASTM, NFPA, UL). The vast majority of these referenced codes will have no bearing on the vast majority of issues you will face, but it is important to understand the depth and complexity of codes.

Let’s pretend, just for the sake of discussion, that you are researching a fairly simple question, and there is only one jurisdiction, and there is only one code book that applies to your question. Even then, in this pretend world, the answer can be very difficult to locate. I might discover the answer to a question about fire alarm systems in an early chapter covering general requirements, only to discover in a later chapter about schools that my earlier discovery was not conclusive to my particular situation. Codes can be deceiving in this way. You can spend an enormous amount of frustrating time trying to find your specific issue and glory in the moment when you hit upon the answer, only to discover later that some exception or situation had you in the complete wrong chapter.

If I am sounding disgusted with the whole process, then I’ve not communicated well. The fact is, I have a great appreciation for these codes, and an appreciation for the immense endeavor it must be to write them. I also have to admit, and I’m sure it is indicative of a sick mind, but I like to read codes and find answers to difficult questions. I have learned that finding answers gets easier as I become more familiar with the code. I have also learned that code officials do not have all the answers. How could they? But since they are the ones who enforce the codes, when I have a tough question, and I am not certain of the answer that my research is providing, I will not hesitate to call on the code official for an opinion.

Back to the original question about occupancy load: the number and size of exits do not determine occupancy load. Rather, the size of the room determines occupancy load…..the bigger the room, the more occupants it can hold. BUT the formula varies by occupancy classification (assembly, classroom, etc)…, for example, the formula for a room classified as “concentrated use assembly without fixed seating” is 1 person per 7 net square feet, while a “classroom” is 1 person per 20 net square feet (NFPA 101, 2006, The occupancy load determines the amount of egress that is required. So a room that can occupy 500 people needs more exit area (size and number of doors) than a room that can occupy 50 people. What is the answer to the original question? The data provided is not sufficient to answer the question. In fact, it doesn’t help at all.

After several years teaching at Father Ryan High School and as the Director of Camp Marymount, Chris moved into technical/management work as Facility Manager of the new Father Ryan High School campus in 1991. Here, he developed the concept for School Facility Management, LLC, and after leaving Ryan he worked for two years in business and finance before founding SchoolFM in May, 1998.

Chris has come to realize that the knowledge base of the SchoolFM staff is the defining value of SchoolFM. Continuing professional development is one of the key components that distinguish high-end facility management professionals from managers who are simply holding things together. Not only does Chris demand rigorous standards of professional development for his staff, he logs hundreds of hours each year toward his own professional development.