MWL Consulting Company NFPA Member since1990 Fire Service Section Fire Marshal (retired) Newport Fire Department Michael W. Leber 17 Whitwell Avenue Newport, RI 02840 Mobile Phone 401-439-5322 mlebernpt@aol.com February 24, 2017 Prepared for: Steve Kirby Kirby Commercial Newport, RI 02840 Property Location: 11 Bowler Lane Newport, RI 02840
Building Summary 11 Bowler Lane is composed of two buildings with a common wall and roof. The larger section is a two-story wood-frame commercial mixed use building built in the early 1900 s. The two buildings are joined and may not be treated separately for fire code purposes. The left (west) structure, as you face it is a brick clad one story office building having around 1370 sq. ft. of office space. The right (east) part of the complex is the two-story wood-frame structure having some heavy timber elements and covering approximately 3500 sq. ft. per level with an additional attached single level garage on the east end having nearly 420 square feet. The roofs of both sections are wood-framed with an asphalt shingle finish. The brick faced section s roof leads continuously up on a pitch up to the peak of the first of two gable roofs over the wood-frame (east) section. There is a concrete block wall between the east and west section that, while providing some fire separation, is not complete enough to claim a rated fire separation. Further, the sections have a common wood roof noted above. There is no space below grade in either section that was observed. Because the sections discussed are not separated and there is no fire separation between any of the various occupied areas of the whole complex it must be treated as a mixed occupancy. This means that the inspector will compare the various occupancy chapters of the fire code that apply and is required to use the most stringent of each chapter and apply that to the entire complex. In this case we are looking at business, storage and industrial occupancies sharing space in this complex. The brick building is ground level only and is office (business) space. The larger two story section to the east has storage areas and light industrial/storage areas. The storage is extensive and dense in areas and is comprised mostly of ordinary combustibles. There is some vehicle and equipment storage along with a wide range of items in the three garage areas on the first level. The rest of the first floor contains more ordinary storage and a workshop at the end of the first floor corridor (approximately 550 square feet). Access to the second floor is by way of an open wooden stair in the central corridor. Almost the entire second floor is occupied by rental spaces used for crafts/artisans of various kinds sail maker-marine craft-photographers-interior decorator-pottery-crafts/storage. These spaces represent the industrial aspect of the occupancy that is more accurately described by the building code as a Factory Industrial F-1 Moderate-Hazard Occupancy that assembles, fabricates, finishes, and repairs etc. materials including: photo equipment, canvas or similar fabric, carpets, clothing etc. There is an additional uncovered exterior stair leading from the pottery space on the NE exterior of the building. It is my understanding that the rest of the occupancies do not have access to this egress because as a private space it is locked when not in use--fire code subclass of industrial occupancy is general industrial occupancy This building is going to be reviewed now under the existing business chapter as it is the most stringent of the three occupancies described. If there is a change of use of the property in the future it will be reviewed by an inspector under the new occupancy chapter. For example, if you made a residential space(s) in place of the existing uses it would require a review under the new (and stricter) chapter of the code. 2
Fire Code Survey The building in this report was reviewed for compliance under the RI Fire Safety Code 2012 edition: FIRE SAFETY CODE SECTIONS 7 AND 8 OF THE RHODE ISLAND LIFE SAFETY CODE 11 Bowler Lane Newport, RI 02840 Section 7 RI Uniform Fire Code 11.1 Electrical Fire Safety. 11.1.2 All electrical appliances, fixtures, equipment, or wiring shall be installed and maintained in accordance with NFPA 70, National Electrical Code. General electrical safety issues such as covers where needed and storage around equipment. 3
Section 8 RI Life Safety Code Chapter 39 Existing Business (Business Occupancy. An occupancy used for the transaction of business other than mercantile.) 39.1.5 Classification of Hazard of Contents. The contents of business occupancies shall be classified as ordinary hazard in accordance with Section 6.2. Ordinary hazard is what is typically found in contents of most occupancies Ordinary hazard would apply throughout. Storage in some areas is very dense with a considerable build up of combustibles. This shows a storage area 1 st floor with significant storage under unprotected wood floor/ceiling assembly 4
If flammable liquids are stored they need suitable storage cabinets. The presence of vehicles and some fuels does not warrant high hazard classification of contents per 42.8.1.5 (Storage Occupancy) 39.2 Means of Egress Requirements 7.2.1.3.6 In existing buildings, a door assembly at the top of a stair shall be permitted to open directly at a stair, provided that the door leaf does not swing over the stair and that the door opening serves an area with an occupant load of fewer than 50 persons. 5
Stair into storage 1 st floor 10.5 inch drop from corridor The hand rail sizing is fine (1 ¾ diameter) but the rail is too high (38 max.) and guards are not provided 7.2.2.4.5.3* Open guards, other than approved existing open guards, shall have intermediate rails or an ornamental pattern such that a sphere 4 in. (100 mm) in diameter is not able to pass through any opening up to a height of 34 in. (865 mm) This means that balusters are required along the length of the rails unless previously approved 6
7.2.2.5 Enclosure and Protection of Stairs. 7.2.2.5.1 Enclosures. 7.2.2.5.1.1 All inside stairs serving as an exit or exit component shall be enclosed in accordance with 7.1.3.2. 7.1.3.2.1 Where this Code requires an exit to be separated from other parts of the building, the separating construction shall meet the requirements of Section 8.2 and the following: (1)* The separation shall have a minimum 1-hour fire resistance rating where the exit connects three or fewer stories. The stairwell is required to be enclosed in a one hour fire separation. This includes walls, doors and hardware and providing a landing as required. The tread depth and riser height of the stairs are within the parameters for an existing stairwell but the open risers are not allowed (suggested in the fire code via 7.2.2.3.3.2 and specified in the building code) The second floor has only this one egress accessible to all the occupants at all times. The exterior stair from the 2 nd floor NE is in a private (and presumably) locked space when not in use. To use the single-exit provision of 38/39.2.4.3, all five of the following criteria must be met: 1. Occupant load fewer than 100 persons 2. Direct exit to a street or to an open exterior area at ground level 3. Total distance of not more than 100 ft (30 m) from any point in the room to the exterior [note that this is total distance from any point to the exterior, not travel distance as measured in Section 7.6; therefore, total distance includes the distance traveled on enclosed stairs (exit)] 4. Stairs not more than 15 ft (4570 mm) in height 5. Stairs completely enclosed with no door openings between the stair enclosure and the rest of the building, or stairs meeting requirements applicable to outside stairs (see 7.2.2.6.3) 7
Exit signage is required. (In the Storage Occupancy chapter emergency lighting is required) 39.2.10 Marking of Means of Egress. Means of egress shall have signs in accordance with Section 7.10. The existing stairwell is considered a vertical opening in the structure and it must be protected against travel of products of combustion. Where an unprotected vertical opening is allowed it cannot be used as part of a means of egress. Penetrations exist in the floor/ceiling between the 1 st and 2 nd floor provide appropriate barrier material. 39.3.1 Protection of Vertical Openings. 39.3.1.1 Vertical openings shall be enclosed or protected in accordance with Section 8.6 If in the judgment of the fire inspector the type of work being done or the hazard of the storage in a section of the building warrants it the space must be protected with a fire separation. If the hazard is deemed more significant the inspector can require fire separation and sprinkler protection for the space. 39.3.2 Protection from Hazards. 39.3.2.1* General. Hazardous areas including, but not limited to, areas used for general storage, boiler or furnace rooms, and maintenance shops that include woodworking and painting areas shall be protected in accordance with Section 8.7. 39.3.2.3 Cooking Equipment. Cooking equipment shall be protected in accordance with 9.2.3, unless the cooking equipment is one of the following types: (1) Outdoor equipment (2) Portable equipment not flueconnected (3) Equipment used only for food warming The fire inspector will make a judgment as to the need for protection of any cooking space. This decision would determine the call for a commercial hood system and fire alarm connection 8
39.3.3.2 Interior Wall and Ceiling Finish. 39.3.3.2.1 Interior wall and ceiling finish materials complying with Section 10.2 shall be Class A or Class B in exits and in exit access corridors. 39.3.3.2.2 Interior wall and ceiling finishes shall be Class A, Class B, or Class C in areas other than those specified in 39.3.3.2.1. Interior finish can be difficult to determine when the specific materials are not known. In this case the minimum rating allowed in exit access corridors is class B. The unfinished wood on the ceiling is probably not going to reach a class B rating as determined by the fire inspector. For example, the rating for untreated southern yellow pine is 130-190 and for oak it is 100. Class B can be 75 maximum and Class C up to 200. It is possible that the other areas with unfinished will be allowed but the exit access areas require a finish that will achieve Class B status. (Storage requires Class C) (Amd) 39.3.4.1 General A fire alarm system in accordance with Section 9.6 shall be provided in all business occupancies where any one of the following conditions exists: (1) The building is three or more stories in height. (2) The occupancy is subject to 50 or more occupants above or below the level of exit discharge (5,000 Square feet). A fire alarm is not required based on the area of the building not being 5000 square feet on a level above or below the level of exit discharge. 39.3.5 Extinguishment Requirements. Portable fire extinguishers shall be provided in every business occupancy in accordance with 9.7.4.1. There are a number of extinguishers placed throughout the building. Placement should be reviewed and starting a regular inspection program would be appropriate. 9
39.5.2 Heating, Ventilating, and Air-Conditioning. Heating, ventilating, and air-conditioning equipment shall comply with the provisions of Section 9.2. Heat is provided in the individual rental spaces by means of natural gas-fired unit heaters and wall units. If installed and maintained properly there is no need for action with regard to them. The Skutt Kiln model KM-822 is a UL listed product that is safe if installed and used according to manufacturers specifications including: A. Install kiln in well-ventilated, sheltered area. Do not permit temperature to exceed 105 degrees F while kiln is in use. B. Provide a minimum of 18 inches between kiln and adjacent walls, other kilns, shelving, and other obstructions. When installing multiple kilns in the same room, ensure that the control boxes on the kilns are not facing adjacent kilns. 10
C. Locate kiln in a room or space with a bare concrete floor. If a bare concrete floor is not available provide a non-combustible substrate and two (2) inches of masonry below the kiln extending a minimum of 12 inches beyond the outside dimensions of the kiln. 39.7.3 Extinguisher Training. Designated employees of business occupancies shall be periodically instructed in the use of portable fire extinguishers. Provide extinguisher training. 11
Summary review These are the primary issues and comments in the survey From the survey General electrical safety issues such as covers where needed and storage around equipment. Ordinary content hazard would apply throughout. Storage is very dense in some locations with a considerable build up of combustibles. This shows a storage area 1 st floor with significant storage under unprotected wood floor ceiling assembly If flammable liquids are stored they need suitable storage cabinets. The presence of vehicles and some fuels does not warrant high hazard classification of contents per 42.8.1.5 (Storage Occupancy) Stair into storage 1 st floor 10.5 inch drop from corridor The hand rail sizing is fine (1 ¾ diameter) but the rail is too high (38 max.) and guards are not provided. This means that balusters are required along the length of the rails unless previously approved by fire authority The stairwell is required to be enclosed in a one hour fire separation. This includes walls, doors and hardware and providing a landing as required. The existing stairwell is considered a vertical opening in the structure and it must be protected against travel of products of combustion. Where an unprotected vertical opening is allowed it cannot be used as part of a means of egress. Penetrations exist in the floor/ceiling between the 1 st and 2 nd floor provide appropriate barrier material. The tread depth and riser height of the stairs are within the parameters for an existing stairwell but the open risers are not allowed (suggested in the fire code via 7.2.2.3.3.2 and specified in the building code) The second floor has only one egress accessible to all the occupants at all times. The exterior stair from the 2 nd floor NE is in a private (and presumably) locked space when not in use. Exit signage is required. (In the Storage Occupancy chapter emergency lighting is required) If in the judgment of the fire inspector the type of work being done or the hazard of the storage in a section of the building warrants it the space must be protected with a fire 12
separation. If the hazard is deemed more significant the inspector can require fire separation and sprinkler protection for the space. The fire inspector will make a judgment as to the need for protection of any cooking space. This decision would determine the call for a commercial hood system and fire alarm connection Interior finish can be difficult to determine when the specific materials are not known. In this case the minimum rating allowed in exit access corridors is class B. The unfinished wood on the ceiling is probably not going to reach a class B rating as determined by the fire inspector. For example, the rating for untreated southern yellow pine is 130-190 and for oak it is 100. Class B can be 75 maximum and Class C up to 200. It is possible that the other areas with unfinished will be allowed but the exit access areas require a finish that will achieve Class B status. (Storage requires Class C) A fire alarm is required if the area of any level above or below exit discharge exceeds 5000 square feet in a business occupancy. In this case the 2 nd floor is approximately 3500 square feet and there is no space below ground level. There are a number of extinguishers placed throughout the building. Placement should be reviewed and set up a regular inspection program. Commentary The owner can anticipate that a full inspection of this building complex may result with a visit to the Fire Safety Board of Appeal and Review to allow a possible compromise on some issues. While being reviewed in this survey as a Business Occupancy we would expect some negotiation is in order given the size of the building and low occupant load. Also some attention must be noted regarding the fact that in practical terms the existing use of most of the space is storage or industrial. Further, there is a degree of separation between the brick faced section and the woodframe section that may be enhanced or even allowed as it stands as a form of separation in its current condition. Proposing to install a fire alarm system increases the chances for success before the Board if that is needed. Regarding the requirement for two exits from the second level when using the Industrial chapter the building comes very close to compliance if the existing open stairwell becomes part of a fire rated enclosure. The guards needed to improve the stairwell may not be necessary if the stair is enclosed (depending on the design used) and the open risers can be corrected at the same time. A fire alarm system in association with a fire sprinkler system would go a long way toward resolving almost any issues that the complex faces and certainly would be welcomed by the local fire inspector and the Board of Appeal and Review. There also should be some resulting benefit with the building insurance premiums. 13
It is common when hiring a fire alarm contractor that the bids include as a package the exit signage and emergency lighting and a Knox Box (locked entry keys for FD) when required with the fire alarm. If the fire inspector decides that areas of hazard need to be protected it could done on a case by case basis in the various rental spaces. If the subject of protecting the cooking area on the 2 nd floor arises then the equipment can simply be removed. Any interior finish deficiency should be able to be resolved with an intumescent paint that improves the surface interior finish rating. Selected Estimated Costs range Fire alarm There can be a wide range in what you can pay for a system that will be acceptable to the Fire Department. Factors influencing this can be the equipment manufacturer, degree of hiding the wiring (unless wireless is chosen) and the biggest difference will be the choice of contractor. $15,000 to $30,000 Stair enclosure $7,500 to $20,000 Intumescent paint and application in all bare wood areas (if needed) $5,000 to $10,000 14
7 Bowler Lane 7 Bowler Lane is a 750 sq. ft. footprint storage building without running water. Heat is provided by individual units within each area and not requiring protection. There is an open space on the second level used as office space. A fire inspector could require an exit sign on the 2 nd floor and emergency lighting in the storage area. 7 Bowler Lane used for storage with accessory office space on the second level Ordinary hazard contents The storage at ground level has side hinged swinging doors locked from the outside. Exterior stairs lead to the office space on the second level. 15
The threshold to the upstairs office space exceeds ½ inch. The door itself is 69 inches in height while 80 inches is required in a new door (see reference to 40.2.5.2.1 allowing tread and riser sizing) The wooden stairs are inconsistent in sizing and shape and the handrails exceed size for diameter width. The exit discharge at base of stairs is uneven. A fire alarm is not required. * MWL Consulting is not responsible for compliance with any codes or other requirements. This survey cannot substitute for a full fire department review.* 16