Camps 'N Codes

Stefanie Smith, LEED AP BD+C
March 2017

For camp administrators, it is all too often that they find their vision of an renovation or expansion project is not in tune with the building codes and regulations enforced by the local Authorities Having Jurisdiction (AHJ). Where camp administrators wish to promote a rustic experience in natural settings, the codes may require sprinkler systems, heating, additional plumbing fixtures, and full compliance with accessibility standards. The codes are often not flexible enough or equipped with sufficient exceptions to address the specific use and needs of camps, especially seasonal camps. There are many regulatory agencies that may impact a project, including but not limited to, building, health, engineering and zoning departments, agencies enforcing accessibility, design review boards, and fire departments.

Building codes and regulations can impact the construction feasibility, the camp’s culture, and ultimately the cost to build or renovate structures. For example, many camps have their own water/system, making the requirement for sprinkler systems costly with the likely need for water storage tanks and pumps. In addition, for seasonal buildings with no heat, the system must be protected from freezing by draining and reactivating the system annually, creating the need for an expensive dry system, or insulating and heating the building year-round. The latter option is not only expensive, but changes the experience and culture of many summer camps.

Building codes and regulations are in place to protect the health, safety and welfare of occupants. Due to the often unique building types and occupancy of camps, some of these regulations can unintentionally exceed a standard level of care. For example, while sprinkler systems are beneficial for life safety and protection of property, the argument could be made that a greater dependence upon fire and smoke detection and alarm systems would be a more rational and cost effective solution for small, unheated cabins that provide very short travel distances to exit doors. Although it takes time and resources to pursue, items such as these have been approved when appealed in many cases.

Before taking on a building project, it is necessary to understand the issues in detail: what agency, department, or code has jurisdiction, how to respond to their requirements and what impact this has on the camp’s finances and vision. To this end, it is recommended that a feasibility study be undertaken at the beginning of each project. Design professionals, such as architects, can assist with code investigations, opinions of associated costs, and alternative design options to achieve the desired goals. 

It is also imperative for the camp organization and professional design team members to meet with the AHJs, including the building official, building inspector or plans examiner, the director of the Department of Health, the fire marshal and any other applicable entities. Their decisions and opinions are key to many of the issues that affect the project during the design and construction phase of the project. It will be well worth the time to meet with these individuals early to inform them of the scope of the project. Although time is a precious commodity, most public officials are generally willing to listen to what is being proposed, explain how to expedite the compliance review process, and discuss points of concern and code issues that are important from their perspective. Building an early relationship may encourage more flexibility when interpreting the code and its application rather than pursuing a variance from the Board of Appeals.

The bottom line to success for any camp expansion or renovation project is to make an informed and rational decision based on local, county, and state building codes and regulations.

CASE STUDY — “FIRE PROTECTION”

A seasonal camp in Pennsylvania planned to utilize a state building code exemption for recreational cabins that would have allowed the omission of an automatic sprinkler system in the renovation of their cabins. However, the building official did not classify the buildings as recreational cabins, thus requiring the addition of sprinklers. The owner and design team appealed the review due to the financial hardships that would be caused by:

  1. Installing water storage tank(s) and pump(s), since the camp was serviced by a well.
  2. Installing a water distribution system to each cabin, sized and designed for sprinklers.
  3. Maintaining the system, which would require winterizing and reactivating the system in the spring, since the cabins would be unheated.

To compensate for the omission of the sprinkler system, the owner’s legal counsel and design team proposed that each cabin would be provided with two readily apparent exits and equipped with smoke and carbon monoxide detectors. Since the seasonal cabins lacked both a heating system and cooking appliances, the fuel source would be kept to a minimum, making the structures less prone to a fire.

The Appeals Board granted the variance to omit the sprinkler system but included the following list of conditions:

  • Limit cabins to seasonal use from mid-May until early October.
  • Prohibit smoking throughout the camp.
  • Prohibit all appliances in the cabins.
  • Limit electrical service to lighting, convenience outlets, and detection/alarm devices.
  • Provide an exit door at each end of the cabin. Exit doors to remain unlocked from the inside and be equipped with panic exit hardware.
  • Provide two smoke detectors and one carbon monoxide detectors, hardwired with battery backup, installed with strobe and horn alarms, inside and outside the cabin.
  • Provide emergency lighting in each cabin.
  • Provide sealed and shatter-proof lighting fixtures.
  • Locate fire extinguishers adjacent to each exit.
  • Prohibit open-flame, gas or propane water heaters within the structure.

Commentary

Although each jurisdiction may have exceptions, most commercial building codes require automatic sprinkler systems in residential occupancies. Under the International Building Code, edition 2009, the model building code in which most jurisdictions base their codes, this typically includes camper cabins. This requirement can create hardships for camp operations considering a renovation project or new construction, especially since the sprinkler requirement does not take into account the camper cabin size, design, occupant load, or seasonal use. Other camp housing types, such as a year-round caretaker’s house, may be considered under residential codes, which generally do not require sprinklers. This classification depends on who is using the building, how long they are staying, the number of occupants, and ultimately, the decision by the local building official.

Beyond housing, camp buildings requiring sprinklers may include assembly spaces such as dining halls and even open-air pavilions, depending on the size of the fire area, occupant load, and other conditions.

It is imperative to engage the project team members early in the process, understand the local codes and meet with the local AHJ to determine requirements that may affect the project’s feasibility.

CASE STUDY — “ROADBLOCK TO CABIN RENEWAL”

A seasonal summer camp in New England proposed to replace some of their deteriorating bunkhouses with new construction. The building permit application was denied by the building official pending the addition of an automatic sprinkler system and the means to maintain the interior environment at a minimum of 68°F, per International Building Code 2009 Edition (IBC). Both of these items were cost prohibitive and incompatible with the desired rustic character of the camp. Rather than providing the most basic protection from the elements, as the program desired, compliance would require a total redesign.

If the buildings were required to be air-conditioned and heated to meet the interior environment requirement, the building would not only need to a heating system, but would also need to comply with the thermal envelope provisions of the International Energy Conservation Code 2009 Edition (IECC), including the addition of:

  • Windows, in lieu of open-air, screened openings
  •  Exterior wall insulation and an interior wall finish material, in lieu of exposed studs
  • Attic and floor insulation

As the building official was not willing to use his authority to accept alternate provisions, the camp’s only remaining option was to devote time and resources to appeal these decisions and seek relief from these issues from the Board of Adjustment. Although the arguments presented to the Board were eventually successful and construction proceeded without the sprinkler and heating systems, the process resulted in a substantial delay. The Board accepted the following conditions proposed by the design team:

•  Additional smoke detectors to be provided, more closely spaced.

•  Interconnected detectors and strobes to alarm adjacent sleeping spaces.

•  Required fire drills to be practiced by campers and staff.

Commentary

In this jurisdiction, the decisions made by a Board of Adjustment did not create a “case law.” As the project is a phased replacement of the bunkhouses, each and every application must be treated as a separate case and proceed through the appeals process in order to obtain the required building permit.

CASE STUDY — “TOILET FIXTURES — WHO COUNTS?”

A recent project to add new camping facilities brought to light that the plumbing fixture requirements of the local county building code, which were based on a “multi-family dwelling” occupancy type, not only contradicted the camp’s needs and budget, but more importantly, conflicted with the regulations of the State Department of Public Health. The building code requirements were nearly twice those required by the Health Department’s Youth Camp Code, (refer to Table 1 for comparisons of codes). After presenting supporting data and noting that the proposed fixture count would comply with the Health Department’s regulations, it was agreed by the Building Official that the State’s criteria more closely represented the camp’s occupancy type and would be used throughout the project.

Commentary

Since summer camps are a unique occupancy type, not typically addressed by building codes, calculating the number of plumbing fixtures required and their location, can be challenging. In addition, there may be other regulations that can have conflicting requirements. This can affect the project’s budget, schedule and vision for camp.

Building Codes typically note that plumbing fixtures are to be located within each building. However, camps often prefer to have cost efficient, centralized facilities, rather than locating the plumbing fixtures within each cabin. Travel distances to these centralized facilities are often not clearly established by Code provisions. Path of travel distances to toilet facilities in occupancies other than covered mall buildings, are limited to 500 feet by the International Building Code (IBC). Some state codes note this distance to be within a 1000 feet walking distance. When locating a restroom and/or shower facility, consider the site’s terrain, environmental conditions, and the occupant’s needs. A shorter distance would likely be appreciated by most campers, especially after dark.

Things to keep in mind when reviewing codes and plumbing fixtures for camp:

  • Consider the occupancy type(s) and how the facilities will be used.
  • Identify locally adopted building codes and other regulations (city, county, state).
  • Research regulations or guidelines, other than the governing codes, that may be more representative of camps. Provide the building official with reputable regulations that can be used to substantiate the needs of camp. 
  • Meet with the building official to review the program and understand the criteria that will be imposed. The building official typically has the authority to consider plumbing fixture requirements for occupancies that are not specifically included in the Building Code.

CASE STUDY — “CAMPS AND ACCESSIBILITY”

With camps trending towards inclusivity, accessibility is often desired, yet can be difficult to provide due to the rustic nature of camp, the site’s topography, existing facilities, and limited budgets. Sometimes, creative solutions need to be found.

At a camp located in the mountains along the west coast, the terrain was so extreme that over 350 feet of switchback ramps would have been required to access the camper cabins. Due to the potential financial hardship, the Building Official accepted an alternate solution that allowed the camp to utilize golf carts to transport individuals with disabilities throughout the site.

On the opposite side of the country, an east coast camp was required to provide automatic door openers at the accessible entrances for their new cabins. The camp argued that this requirement is “alien” to rustic cabins, and is meant for non-transient dormitories, not transient camper cabins. The appeal was successful and the cabins were still designed to be fully accessible minus the automatic door openers.

In an effort to provide cost efficient, accessible restrooms, another camp was permitted to provide an accessible unisex restroom rather than renovate their existing restrooms. In this case, the solution also addressed a requirement for a “family or assisteduse toilet and bath room,” since it was considered a “recreational facility.”

Commentary

In most locations, there may be several regulations governing accessibility. What is required?

The Americans with Disabilities Act (ADA) is a comprehensive federal civil rights law that prohibits discrimination on the basis of disability. The ADA Accessibility Guidelines (ADAAG) applies to all new construction and alterations. Building Codes also include accessibility requirements that may be augmented by Local and State jurisdictions. While the Architectural Barriers Accessibility Guidelines; Outdoor Developed Areas only applies to projects using federal funds, it is a good resource for accessibility requirements of outdoor features including access routes, picnic areas, camping, viewing areas, trails, and beach access: https://www.access-board.gov. Note: When requirements are conflicting, the more stringent technical requirement that provides greater access for individuals with disabilities should rule. 

When renovating a primary function of a facility, accessibility upgrades to the path of travel to the renovated area, the restrooms, telephones, and drinking fountains serving that area may also be required. If the cost to provide this level of accessibility exceeds 20 percent of the cost of the alteration to the primary function area, provide accessible elements in the following order of priority:

  1. An accessible entrance;
  2. An accessible route to the altered area;
  3. At least one accessible restroom for each sex or a single unisex restroom;
  4. Accessible telephones;
  5. Accessible drinking fountains; and
  6. When possible, additional accessible elements such as parking, storage, and alarms.

As most camps were built before the accessibility requirements were in place, many camp facilities and amenities are not accessible. Providing accessible building entrances are a common issue at camps, especially if the buildings are raised above grade and require stairs to enter the building. In addition, doors are often too narrow and have door knob hardware that is difficult to operate. All camps should have an Accessibility Implementation Plan, to address the removal of barriers required by the ADA. Having a plan in place will help identify accessibility issues, possible solutions and a timeline for when each solution will be realized, potentially reducing liability. A good reference for evaluating and prioritizing site and building accessibility is the ADA’s “Checklist for Readily Achievable Barrier Removal”: http://www.ada.gov/checkweb.htm