Codes and standards are a basis of building and facility design. Even with the best of intentions, sometimes code requirements are at odds with a building’s usability while offering no clear benefit. The SSA advocates for commonsense changes to the national model codes and standards to increase efficiencies and limit costs for facility construction. In 2021, SSA plans to pursue further modifications to the codes outlined below with the assistance of code consultant Andrew Klein.
Fresh air intake: To promote ventilation, the mechanical code requires a minimum outside air intake per area of occupied building. When applied to self storage, this requirement leads to illogical results because some code officials include the storage units, which are not occupied, when calculating the floor area to determine the total fresh air intake. The greater the fresh air intake, the higher the HVAC equipment costs and energy costs to run the equipment. Furthermore, oversizing equipment limits an air conditioner’s ability to control humidity. By clarifying that the storage units are not part of the occupiable floor area, the minimum fresh air intake rates can be properly calculated and consistently enforced.
Radio repeater: New buildings must have approved radio coverage for emergency responders within the building based on existing coverage levels of the public safety communication systems utilized by the jurisdiction, measured at the exterior of the building. There is some ambiguity in the requirement in terms of how a building owner shows that it is compliant. SSA will participate with several other interested organizations as standards for this issue further develop.
Unit lighting: Many jurisdictions already do not require lighting inside of individual units because they are not considered occupiable and there is a safety concern of tenants using electricity for personal use and unregulated activities. Some code officials disagree and require lighting inside of individual units. The SSA’s proposed code change would confirm that providing light inside of units is unnecessary from a safety perspective, and therefore is not required.
Restroom spacing: An exception has already been added to 2021 I-Codes to permit an increase in the location (to greater than every other floor) and maximum distance of travel (to greater than 500 ft) for restrooms. The location and travel distance must be approved by the code official. Because storage facilities have extremely low occupancy rates, it is not a cost-effective use of space or resources to require the same number of independent restrooms when they will rarely be utilized. This provision would be proposed to the Uniform Plumbing Code next cycle.
Access-controlled areas: The occupant load in a building is the basis for determining many code requirements ranging from egress to ventilation and many in between. There are currently no provisions in the code for determining the occupancy load of access-controlled areas, like many self storage facilities are. A proposed code change has been submitted to allow historical entry log data from similar facilities to be used as the basis for determining the maximum occupancy load of access-controlled areas.
Elevator Backup Power: The code requires all buildings to provide backup power for an elevator if it is five stories or more in height for both egress as well as for firefighter use. We have proposed that 5- and 6- story self storage facilities, where all accessible units are on the first 4 floors, be exempt from requiring backup power for an elevator. This would save considerable money by avoiding the need for a generator in such facilities.
SSA will submit these proposals in January for the next code cycles. SSA members can review the status of these proposals here.
Please email Joe Doherty or Daniel Bryant if you have any questions.
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