Building Codes: What's So Unified About It?

In the span of an hour or two, my work can take me through several states in multiple time zones.  You would think that the efforts involved in the late 1990’s to create unified codes would have helped firms like ours that works in many states.  This, unfortunately, is not the case always.  Those responsible for building code compliance must be ever vigilant in their efforts to satisfy all requirements.  I routinely am asked questions about our various projects and I invariably have to interrupt the question to ask, “Where are we?”  Building codes, like real estate, are tied to location, location, location.

The International Code Council was formed in the 1990’s in an effort to combine the three model codes used throughout the United States at that time.  For what it is worth, this was accomplished as BOCA (Northern States), SBC (Southern States) and UBC (Western States) combined into the International Building Code family in 2000.  The problem lies with State and or Local adoption and to which version, as the ICC codes are updated every three years.  Just because the code is updated does not mean it is enforced.

The first step of code compliance satisfaction is to determine the prevailing code of the land.  This process should be easy, right?  Well, no.  We do have some tools to help us by the folks that write the codes. The following link to the ICC website identifies the adoptions by state:

www.iccsafe.org/gr/Documents/stateadoptions.pdf

The link does help narrow down the search for the 50 states and 5 territories.  However, if you look closely, some adoptions aren’t state wide.  In some state, like Delaware, they are adopted by County.  In some states, it is even by City.  The link above does give us a really good start on this and in most cases I’ve run across, lists each local municipality by name and what they each have adopted, as well as key contact people at the State.  But it is always best to check with each municipality to see what amendments there are to the adopted Code.  Sometimes there are none.  But not likely…

Currently, there are states using 2003, 2006, 2009, 2012 and 2015 editions.  Some states even use different editions within the family of codes, including Fire, Plumbing, Energy, Mechanical and others.  And many States have either the own code published by ICC or have amendments to the code that can be inserted into the standard code.

A few of the State code books I need to reference at my desk currently.

In our home state of Pennsylvania, a significant issue arose when considering adoption of the 2012 IBC and IRC (International Residential Code).  The main issue was dollars.  Builders and Owners had major concerns about the cost of new requirements in the codes.  The new codes effectively required a form of automatic sprinklers in every new dwelling built – even single family houses.  Without discussing all the litigation, the main effect was that PA has been stuck on 2009 IBC/IRC since.  To make matters more confusing, the State has since adopted select sections of the 2012 Code that affect accessibility.  So essentially, whenever building in Pennsylvania, one must use the 2009 IBC, but utilize Chapter 11 of the 2012 IBC, plus Appendix E, plus sort through all the other chapters of the 2009 Code that may have reference to accessibility.  Believe me; no one likes this process – not architects, not building code officials, no one.

Well used and well loved - some of the 2009 ICC family of Codes.

If that weren’t enough, there are other codes out there.  NFPA (National Fire Protection Association) has been around for over 100 years.  They produce codes and standards on many things; from the very specific, like commercial cooking hoods,  to the very broad, like their own building codes.  In the 1990’s there was an effort to fold NFPA codes into the ICC family, but it didn’t pan out.  Some jurisdictions enforce compliance to these codes in addition to the ICC codes.  This of course produces conflicts for those trying to comply with all applicable codes.  Example: one code says the dead end corridor is limited to 20 feet, the other 30 feet.  In this case, one must limit the dead end corridor to the most stringent or 20 feet.  It can get significantly more complicated, when multiple conditions must be met in both codes in order to provide some feature otherwise limited by one or both codes.

Some of the hundreds of NFPA standards and regulations.

In some cases, the next edition of one code may address the inconsistency between the two codes and the two finally align, but that only helps us when the jurisdiction we are working in adopts that code, which could be 10 years away, depending on the State.

The building codes, for the most part, address life and building safety.  There are other regulations that address operation.  For our firm, we routinely encounter these kinds of guidelines with health departments.  Whether it is a swimming pool, a commercial kitchen or a skilled nursing facility, there are more regulations.  These can have to do with lighting levels, air changes or distances from a care bases to a patient room.  These regulations can be at a city, county or state level as well, so more research must be done in order to ascertain who has jurisdiction over a particular project.

Another recent, national guideline like this the Facilities Guideline Institute.  It pertains to health care facilities and the like.  It is more of a minimum set of operations, equipment and facilities in health care related occupancies.  Some States have adopted this guideline while other States have their own set based on licensure requirements.

State licensure regulations affect building design and compliance.

There are also federal laws, like the Fair Housing Act, the Americans with Disability Act (ADA), and the Architectural Barriers Act.  The ADA is a law, not a building code, so while our plans are not reviewed or approved by any entity, failing to comply can and will be enforced by litigation.

Buildings themselves are a complex set of coordinated efforts to provide a healthy and safe living environment.  The vast web of building codes, operational requirements, safety guidelines and federal laws are an integral part of this process.  There is not a single source for any compliance issue.  A single project may have multiple authorities that review or approve construction plans.  As such a single project may be required to be compliant with multiple codes or regulations, and those regulations may not always agree.  The authorities granting occupancy don’t always agree.  As architects, we play the role of Chief Compromise Officer.

A Walk in Their Shoes, a Window into Their Life

One of our firm’s primary concentrations is on Senior Housing.  A growing trend in CCRC’s (Continuing Care Retirement Communities) is to provide dedicated memory support units for personal care or skilled nursing.  In fact, one of the first buildings I worked on at RLPS during my internship was a new building that contained both under one roof, just a few miles from our office.  Coincidentally, my grandmother wound up living there for several years.  You can imagine, through all my visits with her, by me alone or with my family, my eye did not stop looking at her surroundings critically.  Whether a room was too small, a ceiling was a little low or a paint color questioned, I continued to critique our work.

Having a frail relative live in one of the spaces you’ve helped create changes how you look at the building.  It quickly changes from “how does this detail work for the resident” to “how does this detail work for grandma?”  In a surreal course of events, I have now had three family members enter senior housing facilities I was directly involved with the design.  My grandfather spent his last seven days in a Hospice facility we designed, my grandmother spent time in both rehab and memory care in another building that I served as project architect.  Even today as I type, my mother-in-law is receiving treatment at a rehab facility due to a stroke.  I can look on a room size or detail and recall the now invisible signs of compromise.  I can literally see through the walls or ceilings and observe the duct crossings under structural members that produce a less than ideal ceiling height.  Was there anything I could have done differently?  Perhaps.  Perhaps not.

But even as I walk through the building with a family member who is now the "resident", there is another personal experience that can help affect design for those dealing with dementia and memory loss.  About a year ago, our office provided some educational training that some may think unusual for a designer in which to participate.  A non-profit organization called Second Wind Dreams has a Virtual Dementia Tour program that helps people who care those dealing with dementia feel the symptoms of dementia first hand.  Most of the designers in our office participated in the program which was held, coincidentally, in one of the same building one of my grandparents had lived.  So it had even more emotional impact on me I think.

The program is fairly simple.  The course-taker is given some of the symptoms of a dementia resident would have and must navigate a typical resident room and complete several everyday tasks.  Easy, right?  Stay tuned.

The course-taker first places inserts in their shoes that gives the fell of pins and needles on the bottom of the feet.  This affects your mobility and provides a nagging discomfort with which you need to overcome.

Then, you have gloves to wear that both desensitize your sense of touch and impair your dexterity.

Next, you get a set of headphones to wear.  And while you hope for some Pink Floyd, what you hear is cars honking, static like when tuning a radio, voices, and other confusing noises - picture walking through a haunted fun house.

And lastly, some cool goggles.  Instead of a rose colored lens, the world is flushed with a yellow fog and I think they were even more provided with some other vision impairing characterizes, but alas, I had to remove my own glasses in order to fit the goggles on my head, so my eyes were at an even harsher disadvantage.

Once outfitted with our gear, the provider gave us several tasks to perform in the room.  The ability to hear was impacted so I am sure I asked a little too loudly for them to repeat the list for me.  Inside the room, we had to first find the articles we were told to use in the tasks.  It was really hard for me to see, and some level of reading and/or writing was required.  I also had to see colors to find a book and move it, and to find a certain sweater and fold it.  I truly felt that there was not enough light in the room, so I kept carrying things to the open window so I could see the task item.  I didn’t even think to look for light switches to turn them on.

An obstacle course, or rather, a skilled care corridor.  Try this with the goggles.

The tingling in the feet was a bit distracting, but the headphones really were.  Several times very loud noises came from nowhere and startled you.  Plus, I am pretty sure I didn’t hear any of the tasks 100% accurately.  I believe I was looking for a green sweater that didn’t exist where I was supposed to be looking for a pink one.  The gloves on our hands made it difficult to sort through laundry, separate plates and bowls, and to write on paper.

While this program is probably geared toward caregivers and family members of those facing the challenges of dementia, as designers, we really found ourselves learning how difficult it is to navigate through a room we designed.

I don't care who you are, trying to figure out where to go in these bathrooms is a challenge.

Lighting is important.  We had all heard that too much light is not good for dementia units and we need to tone down light levels and glare so residents are not upset, but ordinary tasks in dark rooms are not possible. 

A bad example of glare at the end of a corridor.  Clean floors, but...

Cueing is crucial.  I didn’t think to turn on the lights because the switches were not easily seen.  The same importance can be laid on toilet fixture locations and where clothing to wear the next day is placed.

A standard method of room cueing - memory boxes with personal items of the residents.

Patience is essential.  It takes ten times longer to do any task in this state.  I needed to hear the directions multiple times, and loudly.

But I can do the tasks myself.  I may need assistance, but need to do it myself.

For more information on the Virtual Dementia Tour, see Second Wind Dreams