“First of all, Miss Turner, returning you to shore was never part of our agreement. Second, you are not a pirate, so the Pirate’s Code does not apply. And third, the Pirate’s Code is more of a set of what you’d call ‘guidelines’ than actual rules. Welcome aboard the Black Pearl, Miss Turner.” — Hector Barbosa, Pirate Captain of the Black Pearl, Pirates of the Caribbean: The Curse of the Black Pearl (Bruckheimer, 2003)
Any experienced professional camp administrator will tell you that running a camp has been changing at a breakneck pace. From employment to food handling to environmental restrictions, keeping a camp inside legal boundaries is a fulltime job in and of itself. One element in particular that has been a hot topic in our practice lately is building codes. Intended to improve building safety, these are much more than “guidelines,” by anybody’s standards; they are, in fact, the instructions by which the construction and renovation industries must operate. Like Miss Turner, camp leaders find themselves more and more trying to negotiate with the pirates who know the rules. And again, just like Miss Turner, they find themselves captive en route to some unknown destination. This time, we’re going to take a broad look at the building codes, and hopefully you’ll be better prepared than the movie damsel in distress.
“Returning you to shore was never part of our agreement . . .”
As the saying goes, “That ship has sailed.” Building codes are an irreversible part of the construction environment and are the rules by which safe, habitable structures come to be. In fact, the International Code Council (ICC) says that all fifty states and the District of Columbia have adopted all or part of their standardized International Building Code (IBC) or International Residential Code (IRC). According to their Web site, the ICC “is dedicated to developing model codes and standards used in the design, build, and compliance process to construct safe, sustainable, affordable and resilient structures” (2013). Most states publish amendments to cure regional conflicts with the base documents, with some jurisdictions adopting only certain volumes (like the fire or electrical codes). ICC’s work encompasses all of the separate elements of residential, commercial, and institutional buildings. Among several others, they address important structural, plumbing, electrical, energy, accessibility, and safety topics.
Let’s begin with understanding that the right set of building codes is chosen by how the structure is to be used. But there are so many different uses for buildings at camp, how in the world are you supposed to know which one applies? One of the most common discussions involves camper cabins, so let’s use that to illustrate the concept. Like any regulation or legal document, the keys to unlock the treasure chest are found in the definitions. Here’s how the ICC frames the purpose of the IRC:
“R101.2 Scope: The provisions of the [code] shall apply to the construction, alteration, movement, enlargement, replacement, repair, equipment use and occupancy, location, removal, and demolition of detached one- and two-family dwellings and townhouses not more than three stories above grade in height with a separate means of egress and their accessory structures.” Reading this carefully, we learn that:
- There are rules governing every imaginable operation, facet, and feature associated with this type of construction.
- There is a three-story limit on structures that fall under these rules.
- Each dwelling must have a separate entrance.
In Section R202 of the code (“Definitions”), we read that a “dwelling” is “any building that contains one or two dwelling units used, intended, or designed to be built, used, rented, leased, let or hired out to be occupied, or that are occupied for living purposes.” So at first blush, it would appear that this code would apply to both the caretaker’s house and camper cabins. But reading further in this section we learn that a “dwelling unit” is defined as “a single unit providing complete independent living facilities for one or more persons, including permanent provisions for living, sleeping, eating, cooking, and sanitation” (emphasis added). So unless the camper cabin in question includes kitchen and dining space, this book of rules (the IRC) applies only to the caretaker residence, and then only if it meets the other criteria (like height, entrances, etc.). The ICC addresses everything else, so camper cabins must be built and maintained according to that set of documents.
Before we move on to that, though, let’s look briefly at the residential code book. These rules are written for home builders and inspectors to read, interpret, and enforce. It includes charts and tables with very specific instructions on how most of the elements are assembled generally using off-the-shelf parts, components, and materials. Further, the code is written with chapters that closely match the order in which construction on a single family home happens: foundation, framing, electrical, plumbing, finishing, etc. This works well for the residential construction industry because despite the finished products looking different, home construction is very standard and consistent from one to the next. For example, there are charts that limit how long a ceiling joist can span without support. If a builder wants a wider opening than that, he must commission a licensed design professional (engineer or architect) to prepare a design that describes in detail what the materials will be and how they’ll go together to accommodate the builder’s requirement. The building inspector, then, defers to the sealed design for all of the components to that element. The rest of the construction, though, continues to follow the prescriptions in the code.
In short, the residential code contains short cuts to “cook book,” black-and-white recipes for constructing or repairing that type of occupancy. Given that residential construction is by far the most common, experience in that sort of work is also very common. Many camps are fortunate to have caretakers and site superintendents with years and years of experience in that industry. Now that you know how little (if any) IRC construction is on camp, you should begin to sense that there is a disconnect between the experience and skill set of the facilities personnel and the rules with which construction must comply. Read on, and you may become even more concerned.
On the other side of the discussion now is the commercial code. It is a very different document, and it’s arranged to allow the design professional (not the builder) the most flexibility to develop custom structures requested by clients. To begin, all of the other building uses (besides single-family homes) must be considered and provided for. This requires that each use be classified and then standards developed for each. For example, in Chapter 3 (“Use and Occupancy Classifications”) Section 310.1 (Residential Group “R”), typical camper cabins most closely match the definition for use classification R-1, whose definition reads: “Residential occupancies containing sleeping units or more than two dwelling units where the occupants are primarily transient in nature, including boarding houses (transient), hotels (transient), motels (transient).” Class R-2 is very similar, except that it speaks to more permanent occupancy (like fraternities, sororities, and dormitories). In fact, only R-1 allows for the transient nature of campers. All of the other design elements — including foundation, framing, finishes, plumbing, fire suppression, etc. — are contained in separate chapters. Within each of those appear specific requirements and exceptions for each of the different classifications.
“Second, you are not a pirate, so the Pirate’s Code does not apply.”
Probably most important is that all of this information is presented within the IBC with licensed professional technical designers in mind as the audience. The pre-engineered tables and information throughout the IRC were developed using specific assumptions, which are at the discretion of the designer in the IBC. Responsibility for everything related to the building falls on the licensed designer. So unless you’re trained to read, interpret, and apply technical rules, you’re simply not able to do anything useful with them. Neither the builder nor the project owner has authority to deviate from the approved plans any more than the inspector has authority to allow deviations. When construction difficulties arise in residential construction, there usually is a work-around somewhere in the code because all of the rest of the work is covered in there. In commercial construction, however, the plans reflect the licensed professional’s integrated work. Changing one thing on one end of the building (like ceiling height) could affect all sorts of things elsewhere in the project (like duct work, pipe access, ventilation, and energy use). For example, rearranging the appliance connections in a commercial kitchen will change where the heaviest loads are. In the context of the IBC, a change to the utility connections may affect the framing of the floor. Within the IRC, the framing is sufficiently robust and the appliances relatively lightweight so that those sorts of changes are inconsequential.
“And third, the Pirate’s Code is more of a set of what you’d call ‘guidelines’ than actual rules.”
This all sounds like a lot of expense and bother. So what’s the upside for camp? There are a bunch of them, but here’s just one. Consider, first, the typical camper cabin. What’s the benefit of the commercial code applying over the residential code? Despite the construction simplicity of the residential code (and your caretaker’s intimate working knowledge of it), all of the elements must be satisfied for the inspector to issue a certificate of occupancy (CO) because they won’t let you live in an incomplete house. As we’ve seen, the residential code applies to “dwellings,” which include all of the bits and pieces of being a complete place to live. So it’s assumed that at the very least, some kind of climate control (heat and/ or air conditioning) is required for the building. The residential code includes requirements for building insulation. In the commercial code, though, that’s been addressed in the energy-use section, which states that if a structure is not mechanically climate controlled, then there is no requirement to comply with the energy code, and therefore no need to insulate the building. Effectively “code pirates” themselves, qualified professional knows which “guidelines” to apply to your specific situation and needs (if you’ve communicated with them!).