DRA Guide to Decisions and Interpretations of the Council, Part 4 - Council Decisions and Interpretations
- PART 1 - GENERAL
- PART 2 - PLAN REVIEW AND APPROVAL
- PART 3 - DRA MONITORING
- PART 4 - COUNCIL DECISIONS AND INTERPRETATIONS
- Appendix A – Alteration Procedures
- Appendix B – Recertification Procedures
This section outlines the decisions and interpretations of the Council as they relate to the services provided by DRA’s. The date of the Council decision or interpretation and the editions of the mandatory building codes in effect at the time of the decision or interpretation are indicated at the beginning of each section. Adoption of later code editions may affect these decisions.
Legend to codes referenced:
IBC = International Building Code
IPC = International Plumbing Code
IMC = International Mechanical Code
IECC = International Energy Conservation Code
IOTF = International One and Two Family Dwelling Code
UBC = Uniform Building Code
UPC = Uniform Plumbing Code
UMC = Uniform Mechanical Code
IRC = International Residential Code
IFGC = International Fuel Gas Code
NEC = National Electrical Code
IEBC = International Existing Building Code
COTF = CABO One & Two Family Dwelling Code
SBC = Standard Building Code
SPC = Standard Plumbing Code
SMC = Standard Mechanical Code
The Council granted a permanent variance to the Texas Commission on Jail Standards in regards to sprinkler systems in jails. This variance applies only to jails built to the Minimum Jail Standards. This variance does not apply to prisons. A sprinkler system will not be required in modular jail facilities if the jail meets the requirements of the Minimum Jail Standards established by the Texas Commission on Jail Standards. The jail must be in conformance with the jail standards requirements for smoke and fume evacuation as well as other requirements concerning smoke detection, flame retardant equipment, furnishings, bedding, etc. The Texas Commission on Jail Standards will be responsible for ascertaining that a proposed facility meets their requirements. DRA’s will be responsible for reviewing the construction documents for proposed modular jail facilities to the mandatory codes governing the IHB program.
July 27, 1989
1988 UBC, 1988 SBC
The Council approved the use of ground anchors as an alternate method of construction subject to the acceptance of the approving agency. The Council determined that ground anchors may be acceptable where a building is placed at a temporary location. It is the intent of the Council to allow the approving agency to decide if the use of ground anchors is appropriate in each case. Industrialized housing cannot be located at a temporary location – the use of ground anchors in the installation of industrialized housing is not permitted.
The following information shall be included in the construction documents for a foundation anchoring system before acceptance and approval:
1. A soil investigation report prepared by a qualified engineer, or if the exact site location is unknown, then a description of the soil type for which the anchoring system is suitable
2. Structural calculations and related plans prepared by a qualified engineer
3. Specifications for adequate corrosion protection for the anchors and associated tie-down system
of Drain from Pressure Relief Valves
October 18, 1988
1985 UPC with 1986 amendments, 1985 SPC with 1986 amendments
The Council interpreted the “outside of the building” as it pertains to the termination of the drain from a pressure relief valve to mean through an exterior wall to the outside of the building, not under the building.
February 22, 1990
1988 UBC and SBC
The Council denied a request for approval to use hardwood plywood as a structural material for shear wall design and construction. The codes do not recognize the use of hardwood plywood as a structural member in shear walls. The Council suggested that anyone wishing to use this product either attempt to change the code through the code change process or obtain a code evaluation report from the evaluation services provided through the code groups or from the National Evaluation Service.
August 8, 1991
1988 UBC and SBC
The Council interpreted the code to require that intersecting corridors constitute a single corridor system and must be considered accessible to all tenant spaces with doors exiting into the corridor. Where required by code these corridors must be of fire-resistive construction.
August 23, 2001
The Council approved the use of a DC dielectric tester as an alternate to the use of an AC dielectric tester. The applied test voltage for testing with a DC tester shall be 1.414 times the value of the equivalent AC test voltage.
Not Recognized by the Mandatory Codes
January 4, 1993
1991 UBC, SBC
The Council approved a motion to allow the use of veneers not otherwise recognized by the codes in accordance with one of the following:
1. An evaluation report exists for the product and the product is used in accordance with that report
2. The building design is totally independent of the material on the outside, i.e., the building will meet all the building code requirements without the veneer.
3. The material has been tested by an independent recognized laboratory and/or meets the standards of a legitimate trade association and that these test or standards prove that this product is capable of carrying certain loads, either laterally or vertically, when attached in a certain fashion. Alternately, a structural engineer may design and certify, through calculations and valid test reports, a material’s ability to perform in accordance with the code criteria.
The veneer shall be used in accordance with the conditions of use for that product as set out by the evaluation report, testing agency, legitimate trade association standard or listing, or structural engineer. Acceptance by the DRA of a product based on a report from a recognized testing laboratory or on standards of a trade association may require the DRA to evaluate the tests and the product to assure compliance with the code criteria.
February 2, 2000
1997 UBC, SBC
The Council was asked to determine when ventilation of rafter or attic spaces was required in accordance with section 2309.7 of the 1997 SBC and section 1505.3 of the 1997 UBC. The Council determined that the DRA’s should interpret when this section applies on a case by case basis. DRA’s shall check local requirements for site specific buildings and document those requirements for their files. For plans on non-site specific buildings approved without ventilation of the rafter or attic spaces, the manufacturer shall include a note under special conditions or limitations that the ventilation of the rafter or attic space shall be in accordance with the requirements of the local building official.
August 23, 2001
1997 UBC and SBC, 2000 IBC
The Council set guidelines for plan reviews and inspections of buildings utilizing membrane roofing systems. The guidelines are as follows:
1. DRA’s shall review calculations and construction documents and specifications of buildings utilizing membrane roofing systems for conformance to the listing on the roofing system and the applicable code sections in chapter 15 of the IBC. Calculations are required for all wind speeds, not just those that may be considered high wind areas. Acceptable listings include code evaluation reports, UL listings, FM listings, or listings from other recognized agencies approved to evaluate and list such systems. Listing reports or information shall include documentation indicating compliance with the requirements of section 1504.1 (wind uplift), section 1505 (fir classification) and section 1507 (material specifications and weather resistance) of the 2000 IBC for membrane roofing systems. The listing reports or information shall be a part of the approved documents.
2. Third party inspectors (TPI’s) shall inspect to the approved documents in accordance with Texas in plant inspection procedures. The listing report information is a part of the approved documents. The requirements of the listing report or information governs over what may be required by the manufacturer’s installation instructions for the membrane roofing system. TPI’s shall assure that the component parts of the roofing system are identified in accordance with the listing on the system. TPI’s shall assure that the installer of the roofing membrane is licensed or approved in accordance with the requirements of the listing on that product or the manufacturer’s installation instructions for the roofing system.
3. Membrane roofing systems used on buildings that meet all code requirements without the roofing system will only have to meet the fire classification requirements of the code. The membrane roofing system must be listed for installation in the way that it will be used. For example, the fire classification listing for a membrane roofing system to be used on a concrete equipment shelter must be listed for installation directly to the concrete roof.
September 21, 2000
The Council was asked if gypsum board is an acceptable compression strip in accordance with section 802.5 of the IOTF. This code section permits a compression strip to be installed between the top plate of the load bearing walls and the roof trusses or ceiling joists provided the compression strength of the material is adequate to withstand the loads transferred through it. The Council approved the use of gypsum as a compression strip in accordance with this section as long as substantiating calculations are provided and these calculations take into account the effects of the temperature and humidity conditions where the buildings are to be located.
This decision applies only to one- and two-family residential structures. There is no similar allowance for the use of a compressions strip in the UBC or SBC.
The compression values from Gypsum Association GA-235-98 may be used for these calculations. However, the calculations must take into account the temperature and humidity conditions where the building will be located. The values reported in GA-235-98 are based on tests performed at 70 degrees F and 50% humidity. The Gypsum Association was unable to supply any data on the effects of temperature and humidity on these compression values. Without further information, the use of gypsum as a compression strip in the State of Texas is limited to areas where the average temperature is 70 degrees F and the average humidity is 50%. Use of data from other sources will not be permitted without a code evaluation report or approval of the Council.
Any manufacturer that uses gypsum as a compression strip per the above guidelines must include a note on the data plate and plan cover page or floor plan that the dwelling may only be sited in areas where the average temperature is 70 degrees F and the average humidity is 50%.
February 2, 2000
The Council determined that unoccupied buildings such as equipment shelters do not need to meet the requirements of the IPC concerning the minimum number of plumbing fixtures. This determination applies only to buildings that are normally not occupied. Please note that equipment shelters classified as a Group H occupancy would still need to comply with any requirements for emergency showers and eyewash stations.
February 2, 2000
All occupied buildings must comply with the requirements of the IPC for minimum plumbing fixtures. However, manufacturers may continue to specify on the plans and data plate of non-site specific buildings without the minimum number of required fixtures that the minimum plumbing fixtures in accordance with the code requirements are required to be located in another building on the installation site.
June 30, 2003
Table 704.1 of the IPC requires a service sink in most building occupancies. The Council does not feel that a kitchen sink would be an appropriate substitution for a service sink. It is the Council’s interpretation, however, that in commercial industrialized buildings with areas of 1,800 square feet or less, a lavatory and water closed would be an acceptable substitution.
The design for commercial modular buildings with areas less than 1,800 square feet that contain plumbing shall comply with one of the following:
1. Have a service sink as required by code
2. Have a lavatory and water closet, thus eliminating the need for a designated service sink
3. Contain a note in the special conditions/limitations section of the plans and data plate that a service sink must be available in another building on the installation site or that it will be added as required by local officials
The design for commercial modular buildings with areas greater than 1,800 square feet shall either have a service sink as required by code or contain a note in accordance with the subparagraph on Plumbing Fixtures, Occupied Buildings in Part IV of this guide.
in public restrooms
February 2, 2000
1997 UBC and SBC
The Council was asked to determine the definition of public as it regards the code requirements for hard nonabsorbent surfaces in public restroom. The Council decided that a small office building with a single restroom containing a single water closet and lavatory could be considered private. The number of the plumbing fixtures in the building must be in compliance with the requirements of the IPC. This does not negate the requirements of the code sections requiring the use of water resistant gypsum backing board in wet areas, such as water closet compartment walls.
around bathtubs in one and two family dwellings
September 20, 2000
The Council approved the use of the specifications found in appendix A.1 of GA-216-96 as a suitable alternate to the requirements of the International One and Two Family Dwelling Code. Section 702.4 requires bathtub walls to be finished with a smooth, hard and nonabsorbent surface a minimum of 6 feet above the floor. Appendix A.1 of GA-216-96 only requires the smooth, hard and nonabsorbent surface to extend 6 inches above the rim of the bathtub for bathtubs without shower heads. Gypsum board behind the surface is still required to be a water resistant gypsum backing board conforming to ASTM C630.
Request for approval of FoamNail
adhesive as an alternate to FoamSeal adhesive
September 21, 2000 (revised October 3, 2001)
1997 UBC, SBC
The Council did not approve the use of FoamNail adhesive as an alternate to FoamSeal F2100 adhesive (reference old ICBO ER #4874, now ICC ES Report #ESR-1028) for the attachment of gypsum board to roof framing members. The Council indicated that FoamNail adhesive needed to be evaluated and approved through the code evaluation service to be accepted under the Texas IHB program.
Update October 3, 2001
A code evaluation report on FoamNail adhesive was issued by ICBO on May 1, 2001. The evaluation report limits the use of the adhesive to nonbearing interior or partition walls and ceilings (reference ICC ES Legacy Report #ER-5904).
September 21, 2000
1997 UBC, SBC
The Council was asked to determine if it was acceptable to attach ½” high strength ceiling board manufactured by National Gypsum parallel to framing members with mechanical fasteners when a water based texture finish is to be applied. Evaluation report #NER-496 lists the ½” high strength gypsum board as a suitable alternative to 5/8” regular gypsum board finished with water-based texture materials. The evaluation report requires the ceiling board to be applied perpendicular to the framing members when fastened mechanically, but permits it to be applied parallel to the framing members when fastened with FoamSeal F2100 adhesive. In modular plants the finished ceiling material is usually installed on the roof trusses prior to the installation of the ceiling assembly on the walls. Installing the gypsum board perpendicular to the trusses in this situation leads to a problem with cracking of the ceiling assembly when lifting it for installation on the module. The Council approved the application of the ½” high strength gypsum board parallel to the framing members attached with mechanical fasteners provided written authorization is obtained from the National Gypsum Company. Until such authorization is received, manufacturers may install the ½” high strength gypsum by National Gypsum Company parallel to framing members only when attached with FoamSeal F2100 adhesive.
Update October 3, 2001
As of this date no written authorization has been received from National Gypsum indicating that it is acceptable to attach its ½” high strength gypsum board parallel to the ceiling framing members with mechanical fasteners. Nor has evaluation report #NER-496 been updated to permit mechanical fastening when the material is applied parallel to the framing members or been updated to recognize the use of FoamNail adhesive as an alternate fastening method.
of HVAC equipment
August 15, 2002
2000 IECC with 2001 Supplement and 2000 IRC with 2001 Supplement
The IECC and IRC require mechanical equipment to be sized no larger than what was calculated. DRA’s are directed to assure that the manufacturer’s assumptions in sizing the mechanical equipment are clear so that the local officials can determine if it is in compliance with the IECC for their area. DRA’s and manufacturers are also reminded that the heat loss calculations can not be in conflict with the energy design features of the house or building. Manufacturers are required to clearly state the assumptions made as to orientation, occupancy load, and any other pertinent information that may affect the calculations use to size the equipment.
The Alteration Procedures and Recertification Procedures are included as appendices to this guide.