As a representative of the Virginia Society of the American Institute of Architects (VSAIA), we do not support the following proposed code change (as was included in the January 12, 2010, Code Update Meeting Package).

1.       David Thomas’ code change proposal regarding Section 109 and the means of egress.

a.       Such requirements were not included in the USBC when we switched model codes from BOCA to ICC, and as such, have not been required since.

b.      Including “detail” and “character” of the exit discharge on the documents could prove problematic.  It would appear this would require occupancy loads be provided for all sidewalks, plazas, and perhaps even parking lots and open areas especially if they are not considered part of the “public way”.

c.       Providing occupant loads “in all rooms and spaces” is contrary to what Chapter 10 allows when assigning occupants to a particular space or room.

                                                               i.      For example, Chapter 10 does not require occupant loads be assigned to toilets, corridors, closets, stairs (egress capacity, but not occupant loads), vestibules, and other such spaces.

                                                             ii.      A larger example would be a “Business” use, which Chapter 10 allows to be taken at “gross”...thus avoiding the need to identify occupants “in all rooms and spaces”.

d.      The current system works, where LAHJ can be flexible in what they will require, and what they do not require.  The proposed code change eliminates the flexibility and in our opinion, has the potential to add confusion as to what must be indicated on the documents and how.

e.      If the Codes and Standards Committee and/or the BHCD believe something should be added back to the code, we propose you accept the VSAIA proposal, which more closely parallels what Virginia required through the “legacy” BOCA codes, and what Virginia architects and LAHJ are more familiar with.