Building Codes a discussion of the UBC, SBC and BOCA requirements is also provided; these discussions are intended to illuminate the IBC requirements for those primarily familiar with one of the older model codes. However, no attempt has been made to discuss state and local codes and amendments. 5.2 LIFE SAFETY ISSUES All of the model codes have one provision or another that conflicts with provisions in other codes and/or is generally considered inappropriate by the parking industry. The NFPA openly acknowledges that its life safety code is focused on fire risks: the operative part of its ttle is “Code for Safety to Life from Fire..." Although NEPA 101 doesn't require sprinklers in open parking structures, it does have some provisions that are more restrictive than the other model codes. For example, stairs in open parking structures ‘must be enclosed. There is a provision to allow the stairs to be open if the walking distance down the stair is included in the path of travel to the exit, but it offen requires more stairs. Either way, construction cost is increased. Walking distance to the stairs from any point on a parking structure floor in an enclosed structure is also significantly less than permitted in other codes. Conversely, NFPA has some bonuses, too: an open parking facility that is 50% open on all four sides may have its travel distance increased from 300 fi. to 400 ft. The increase, in tum, can allow open stars to be used in many structures with three or four supported levels, without penalty under NFPA. UBC, in tum, has long had a provision that open parking structures cannot be part of mixed-use buildings, except for the specific combination of an open structure over an enclosed one. If any other occupancy classification is included in building with an open parking structure, the ‘occupancy classification of the parking siructure defaults to an enclosed structure. SBC, NFPA and BOCA however, have allowed open parking structures for an equally long period of years to be part of mixed-use buildings, if separated appropriately. Although building officials in some cities will have at least some experience with parking structure issues, other members of the code organizations have little-to-no experience base regarding the application of requirements to parking facilities. When asked to interpret an issue locally, they naturally make their decisions from their personal knowledge base: the well-established principles of life safety for other building types. W! understandable, it therefore often takes some education of local officials regarding the design issues and constraints for parking facilities.8 Parking Structures ‘The lack of familiarity of parking issues also results in language slipping into the national codes that cause problems for parking designers. For example, IBC contains a provision that effectively limits parking ramp slopes to 1:20, even though slopes up to about 1:15 have been regularly used in parking structures across the country with no apparent egress problems. It is believed that no one in the code organizations even contemplated the application, much less the impact, of this provision on parking design. The intent is to “mainstream” accessibility into means of egress. However, accessibility laws require that those with mobility impairments be given special parking locations closest to the pedestrian entrances and with the path of travel meeting all requirements for accessible routes. Therefor designing the path of travel across a parking floor to mect accessibility criteria is not the issue it can and should be in other building types. The code groups did, in fact, make exceptions to the ramp requirements for theatres. There are also special locations for accessible “seating” that make it less critical for theatre aisles to be accessible, Theatres are a use with much higher risk to life safety in fires than parking facilities. Presumably, the code groups would be willing to make appropriate exceptions for parking if the situation is brought to their attention. In most cases, the parking industry is equally, if not mote, at fault for not following the code change process more closely. Often, only after the code is in force has the industry recognized a problematic, albeit un-intentioned, impact on parking structures. The parking industry has had representatives on the NFPA 88A committee for many years, but that document is rarely if ever adopted and enforced. Its primary benefit is in the education of local officials as to what represcntatives of a cross-section of interested parties agree upon as a consensus standard. Similarly, because fires are so rare in parking structures, the majority of fire protection officials dont have enough experience fighting fires in parking structures to understand the unique characteristics of such events, Even though the national codes, including NFPA 101, have considered and adopted special considerations for parking structures based on studies of the risk to life safety in actual parking structure fires, officials often have added requirements, such as sprinklers, back at the local level. It therefore may take an effort to educate local officials regarding the documented risks to life safety from fire during the building code approval process for a specific project. Almost uniformly, if presented with the proper, well-documented information, local officials will scriously consider requests and make well- reasoned decisions. Therefore, the following discussion of life safety issues in parking structute fires is presented so that designers, owners and local officals alike ‘may agree upon appropriate life safety requirements in parking structures.Building Codes a Certainly, fire safety remains the single largest factor driving all building codes, because the loss of life in fires often could have easily been avoided. The history of parking structure fires proves beyond all reasonable doubt that the risk to life safety from a fire in a parking structure, whether open or enclosed, is very, very low. Indeed it has been asserted, and never disproved, that there has never been a loss of life solely resulting from a fire that began in a parked vehicle. The deaths that have been documented were directly the result of an explosion, caused by either an intentional attempt at murder (such as a car bombing or terrorist act) or improper handling of explosive materials (such as welding during construction or repairs to 2 facility.) And once a fire starts, it simply doesn’t spread very far, at least as compared to other uses. Because vehicle fires are so localized, a sprinkler head that is not directly above a burning vehicle may not activate at all. The buildings are constructed of non-combustible materials that resist fire spread and indeed suffer very little damage in the fires that occur in parking structures. Most importantly, there is generally 2 very low density of ‘occupants as compared to the volume of space, so that the potential for panic during exiting is considerably reduced. ‘A1972 report that was updated in 1977"? was one of the first analyses of actual parking structure fires. It documented the findings of a survey of 1,686 patking structures of all types, sizes and construction totalling over 775,000 parking spaces. During the history of these structures dating to as far back as 1911, $00 fires were reported. Only nine of those fires caused more than $5000 damage. Seven of the nine started as a result of a fire in an auxiliary space such as an office or storage; a gasoline truck overflow and a car bomb caused the other two. The Scranton Fire Tests of 1972" focused on the potential for damage to structural elements from fires and found that even unprotected steel suffered no permanent damage from @ fire that was intentionally allowed to spread to three vehicles. Windows in the three cars were left partially open and the foot wells of the passenger compartments were “stuffed” with crumpled newspapers to encourage fire spread. However, only the plastic tail light assembly on one of the adjacent cars bumed when exposed to flaming ‘gasoline after the gas tank on the first car failed. The fire did not spread farther into that vehicle. The fire did spread to the other adjacent car, apparently originating in a fiberglass repair patch on a door. The fire spread through the door into the passenger compartment, but bumed so slowly that general involvement of this vehicle had not occurred when the tests were stopped 40 minutes after the fire was started in the first car, which was totally burt out. Maximum temperatures and deflection of the structural10 Parking Structures steel remained far below critical levels throughout the test and no damage to the steel occurred. Additional tests were conducted in Australia in 1985 to address the issues of increased use of plastics in cars, the reduction in parking stall widths due to smaller vehicles, the use of plastic gas tanks and LPG cylinders, and the increasing use of lighter steel structures."* The test structure was constructed of stecl members representative of the smallest members likely to be used in practice in an open-deck car park. In the first test, only the car in which the fire was started burned. After 25 minutes, the fire spread to the gas tank filler pipe and the gas from the tank continued to bburn for another 30 minutes. In the second test, the car set on fire had a LPG eylinder rather than a gas tank. 14 minutes after the fire was started, the pressure relief valve on the LPG tank vented to relieve the build-up in pressure in the tank. The gas continued to vent intermittently but never ignited. This fire did spread to the cars on each side. The fire finally spread to the filler pipe of one of those two cars (after $0 minutes), and again the ges was consumed by fire. In both tests, the car park was loaded with vehicles on the floor above and it supported those loads throughout both tests without any noticeable stress or risk of collapse. The measured stcel temperatures showed a significant factor of safety as compared to temperatures expected to cause the beams or columns to “shed load.” Another detailed study" of all fires reported in parking structures, both ‘open and enclosed, by the National Fire Incident Reporting System from 1986 through 1988, in parking facilities of all types (both open and enclosed), found a total of 404 fire incidents. 80% of the fires were vehicle fires. Most (94%) of the vehicle fires originated in the engine compartment; half of those were electrically related. Approximately 72% of the fires were extinguished by fire-fighters. Of the “serious fires” which were defined to bee those that spread to at least one adjacent vehicle, the fire department extinguished 93% of the fires. No deaths were reported and only three civilians and six fire-fighters \were injured; none of the injuries were caused directly by either the fire or the smoke thereof. Note again that this study included both enclosed and ‘open structures. The overall conclusions of this study are as follows: ‘Parking structure fires are extremely infrequent compared to other building uses; they rarely spread from the point of origin; they result in very litle property damage; personal injuries are rare; and no one died in a packing structure fire.Building Codes MW ‘The three model eodes have long since recognized both the low fire risk and the higher violent crime risk and allow open stairs and other considerations for passive security in open parking structures. AS discussed in the chapter on Security, the National Institutes of Justice'® reported about 1,400 violent crimes per day in parking facilities in the United States in 1992. NFPA, however, continues to require enclosed stairs or to place restrictions that generally cause most designers 10 give up the passive security concem and enclose the stairs. Similarly, each of the other codes enforces at least some requirements that are considered unnecessary and a ‘waste of resources that could be put to better use. But again, a key reason for the lack of recognition of unique issues regarding parking in building codes is the lack of active involvement in the code development process by parking designers. ‘The bigger problem that frequently occurs is that local officials want open parking structures to be sprinklered even though all of the national codes are very clear that sprinklers are not required. A more comprehensive discussion of the literature regarding sprinklering parking structures therefore follows. In the above-cited survey of fires, which occurred from 1983 to 1985, fire sprinklers extinguished only 1.4% of the incidents. Seventy-six percent of the parking structure fires were extinguished with hand-laid hoses from fire trucks or with fire extinguishers. Standpipes were used in 11% of the fires. The remainder bumed themselves out or wete put out by occupants of the building, It is true that only 37.4% of the structures had sprinklers; however, in those cases, the fire was controlled or extinguished by sprinklers in only 13.6% of the fires. The two primary reasons the sprinklers were not considered effective by the survey respondents was either that the “fire was too small” (54.9%) or the “sprinklers were not in the area” (42.9%) A second data analysis using only the serious fires in sprinklered buildings found that sprinklers controlled or extinguished only 20% of those fires. Fire sprinklers are considered a key component in life safety provisions in most buildings to contain, if not prevent, fie spread long enough for the ‘occupants to safely exit and/or for the fire department to arrive and take charge of the situation. Sprinklers may be ineffective in achieving these goals in parking structures when fires start in and are generally confined to the protective metal shell of the automobile, especially if they smoulder for a long period. There will usually be enough smoke from a smouldering fire to alert the occupants to a problem without reaching the levels at which egress is hampered by smoke. In the Scranton fire test, a heavy layer of smoke about three ft. thick rose to the cciling, but the openness of theR Parking Structures structure allowed it to migrate out of the structure so that it never became thicker. Sprinklers spraying water on the roof of a car will not extinguish a fire inside or beneath the automobile, at least as an early intervention method. In addition, water from sprinklers has been shown in some tests to actually facilitate the spread of fire from one vehicle to the next. "” Gasoline and water do not naturally mix; the relatively small volume of water from sprinklers tends to carry flaming gasoline down parking floors sloped for rainage oF floor-to-floor circulation, Indeed, sprinklers are prohibited in parking occupancies, including enclosed and underground facilities, in some jurisdictions in Europe because, in addition to failing to control or extinguish fires in test vehicles, the extinguishing water caused more smoke, leading to loss of visibility ‘Tests conducted in Switzerland '* in 1970 specifically modeled three different types of fires in enclosed parking structures. In the first test, a “smouldering fire” was set inside the vehicle. The fire smouldered inside the car for more than 25 minutes before it flared up inside the car. An automatic fire alarm activated shortly before the flare up, at 23 minutes, 30 seconds. Although smoke was produced before the sprinklers activated, it did not fill the test “room” and visibility was good. At 28 minutes, 30 seconds after the fire was sct, the sprinkler system activated whereupon smoke completely filled the room. No fire spread occurred with this fire. ‘The second Swiss test simulated a “clumsy topping off” with ignition of gas spilled from an open gas tank. An intense fire immediately occurred outside and under the vehicle, The sprinkler system activated at 40 sec after the fire was set and smoke “greatly intensified” immediately thereafter. The extinguishing water then spread the fire to the adjacent vehicle. Even though there was mo damage to the inside of the first car, the fire attacked the adjacent car at the front tire, bumed through the engine compartment, and ignited the interior, all while the sprinklers were activated and operating. The fire brigade “standing by” then ordered the test facility evacuated and the sprinklers tumed off. They extinguished the fire using foam but had to use breathing apparatus due to the quantity of smoke. ‘The third of the Swiss tests was intended to model an arson event; the interior of the car was loaded with combustible materials, including tires, plastic waste materials and celluloid. For this test, the sprinkler system was dcactivated, as one of the goals of this test was to study the smoke produced by the combustible materials. The fire was begun by igniting a gas/oil mixture placed in a pan on the floor under the gas tank. The car was blazing with flames shooting out of the gas tank filler cap within 30 seconds. The gas tank, despite being directly exposed to the fire, did not explode or fail, although the contents burned as they escaped via the filler pipe. However,Building Codes 13 the tres of the first vehicle exploded and the fire spread to the adjacent car ‘when its tire caught fire. The interior of the second car did not ig the windows remained intact. ‘The Swiss study concluded that an automatic fire detection system alerting the building occupants and allowing the fire department to be summoned was more effective than sprinklers for underground, enclosed structures. Additional tests in Australia in 1988 studied the issues of fires in enclosed structures." This study found that sprinklers did control and extinguish fires set in vehicles and reduced the amount of smoke. The Gifference in results from the Swiss tests may be due primarily to differences in the way the fires were set. In the Australian tests, the fires were started by placing gasoline-soaked rags under the front seat and lighting them through an open window on the driver's side. The fire broke the windshield very quickly (within one minute or less after the fire was ignited) and the sprinklers then extinguished the fie before it spread further; it never engulfed the vehicles. In additional tests, where sprinklers were not automatic, the fires continued until the vehicles were engulfed; in some ceases the fires did spread to adjacent vehicles. ‘The Australian fire tests also included some interesting tests specially constructed to determine problems resulting from plastics used on the exterior of vehicles and in gas tanks. The conclusion of that study was that the vehicles with extensive plastic did produce more smoke then older vehicles with less plastic and steel gas tanks, although the toxicity of the smoke in both cases was not measured. The Australians also raised the concem that the “venting” of LPG cylinders that occurred when fire heated the tanks is more of a concem when the gas doesn’t immediately burn than it would be if it burned immediately after release, particularly in enclosed structures. In sum, sprinklers in parking structures probably are a “mixed bag.” They appear to be effective in containing certain types of vehicle fires, but not others. The smouldering fire of the Swiss tests, in which sprinklers clearly made things worse, is believed to be more likely to occur than the very rapidly-built fire of the Australian tests. The data on fire history further seems to indicate that sprinklers, even when provided, are not very effective in actual parking structure fires. The cost-effectiveness of sprinklers in both ‘open and enclosed structures is thus questionable. And if the specific circumstances of the fire are such that sprinklers increase smoke or spread fires ftom vehicle to vehicle, as has been proven to occur in some circumstances, they may do more harm than good. In open parking structures, there is enough natural ventilation to allow smoke to dissipate and the documented risks to life safety are low.4 Parking Structures Therefore, it makes sense to simply let the fire bum until it either bums itself out or the fire department arrives to put it out. ‘The issues relating to enclosed structures are mote difficult, because the smoke produced in both the Swiss and Australian tests was significant enough to hamper egress by occupants. However, in the smouldering fire of, the Swiss tests, there was more than enough time and warning for the occupants to evacuate before the smoke affected egress. Therefore, we believe that it may be more appropriate to employ automatic fire detectors rather than sprinklers in enclosed structures, as required in many Jurisdictions in Europe. However, today’s codes in the US uniformly require ‘sprinklers in enclosed structures, 5.3 BASIC ISSUES Building codes recognize two fundamental types of parking structures: the open parking structure and the enclosed parking structure. An open parking structure is one that is sufficiently open to allow natural ventilation as well as dispersion of smoke from any fire, thereby reducing hazards to the occupants. There then devolve distinet differences in the requirements for design that, in tum dramatically affect construction cost and other factors. When a structure does not qualify as open, it must comply with the requirements for enclosed parking structures, which means sprinklers and ventilation, enclosed stairs and so forth. It behooves the parking designer to assure that a facility be able to qualify as open wherever possible. 53.1 Open or Enclosed? ‘An open parking structure is defined by IBC as follows: swith the openings es described in Section 406,3,2.2 on two or more sides and which is used exclusively for the parking or storage of private motor vehicles as described in Section 406.3.4 (IBC 406.3.2.1), The intent of the word exelusively as used in the IBC definition is of concer to the parking industry, because it came from UBC. As previously noted, that code prohibits open parking structures from being part of non- parking mixed-use buildings. UBC hes consistently indicated in formal interpretations that the word “exclusively” is intended to generally prohibit the incorporation of open parking structures in mixed-use buildings. IBC also uses UBC language repeating the word “exclusively” specifically as regards to uses.Building Codes 93 cor numbers shall be a minimum of 3 inches in height and a minimum stroke of % in. ofa contrasting color to the background itself. (IBC 501.2) 5.10 REFERENCES Incernational Building Code 2000, Falls Church Virginia: Imernational Code Council acc) * 1999 BOCA National Building Cade County Club His, Hinois: Building Officials and Code Administrators Intemational, In. (BOCA) > 1997 Uniform Building Code White Califia: International Conference of Building Officials (CBO). Standard Building Code, 1999 edition, Biminghas, Alabama: Southern Building Code Congress International (SBCC) * NEPA 101 Code for Safety 10 Life from Fire in Buildings and Stractres. 2000 Kition. Quincy, Massachusets: National Fire Protection Assocation “NFPA 684 Standard for Parking Sructres 1998 Editon. Quney, Massachusetts: National Fire Prowetion Association, Architectural and Transportation Barriers Complisnee Board, 1991. Americans. with Disabilities det (ADA) Accessible Guidelines for Buildings and Facies, Final Guidlines, 36 CFR Part 1191, uly, 191 " ANSI A117.1-1980, Accessible and Usable Buildings and Facies, American National Standars institut, Ine. ICC/ANSY A1I7.1-1998, Accessible and Usable Buildings and Facilites, ntemational Code ‘Council /Amerian National Standards Istitt, Ie. "© Architectural and Transporation Barricrs Compliance Board, 1999. Americans with Disabilities Aet (ADA) Accessible Gulden for Buildings and Facilites; Architectural Barriers Act Accessibilty Guidelines, Notice of Proposed Rulemsking, 36 CFR Part 1190 and 11911, Noverber 16, 1999. ® Ruth, Jali. “The New Inveational Codes and What They Mean to Window and Door Manufactures”, Window and Door Janary 2000. Haris, Lei, “1979 Update of the Survey of Fire Experience in Automobile Parking Structures in the United States and Canada”, Teaneck, New Jersey: Marketing Research ‘Associates, January 31,1979 © Automobile Burn-Out Test in an OpenAir. Parking Structure, Report No. 7328, ‘Westchester linos: Gage-Babcock & Associates, January, 1973, % Bennetts, Pros, Lewis and Thomas, Oper-deck car park fire tes, Wayalia, South ‘Austalia: BHP Ste! International Group, August, 1985 Denda, Dalo F, Parking Structure Fires, MeLean Virginia: Pking Matket Rescarch Company, Apr 1992 USDOL, 1992,Criminal Vitimization in the United States, US Deparinent of Justice. "Belles, Donald, “Are plastic fel tanks safe?" “Swiss Tests on Fire Behaviour in Enclosed and Underground Car Parks.” Fire International Volume 33, Saly 1971. ™ Bonnets, Proc, Lewis aod Thomas, Fire ane unprotected see! in elosed car park, ‘Whiyali, South Ausalia: BHP Sel Tntcrational Group, 198894 Parking Structures * 1999 BOCA National Building Code Commentary Coustey Club His, Minos: Building Oficial and Code Administrators Iteration, ne. (BOCA) * NEPA 220 Standard on Types of Bulding Consrucion 1999 Bion. Quincy, -Mastashsot: Nationa Fire Potetion Assosstion % ASME A171, 96 eon with 97 and 98 amendments. New York: American Society of ‘Mechaisal Engineers 96 edition wih 97 end 98 amendment ® Handbook to the Uniform Building Code. Whiter, CA; Intemational Conference of Building Ofcials. May 1998. ® ASCE 7-95 Muimum Design Loads for Buildings and Other Structres. New York: “American Socoy of Ci Engnoors