HomeMy WebLinkAboutCorrespondenceFROM : m PRESS ink.
SENT VIA PAX
FAX NO. : 970-625-0843 Dec. 10 2010 11:051:111 P1
r,,+,.
Mr. Matt Provost, Building Inspector
Garfield County Building & Planning Department
108 8th Street, Suite 401
Glenwood Springs, Colorado 81601
RE: Final Inspection at 6702 County Road 309
Dear Matt,
6691 County Road 309
Parachute, Colorado 81635
29 Nov 10
Upon discussion with Keven Rector, Technical Services Manager at NUDURA, I am again
requesting reconsideration of the thermal barrier requirement you have placed upon the barn. This was
not in the pians because of NUDURA's statement that an interior finish is not required on this structure.
A code advisor at the International Code Council provided this information to Mr. Rector. With
the description of barn, shed, private garage or outbuilding in a rural situation, it is classifiable as
Utility Occupancy, defined under Section 312. My structure meets this definition.
Then, under Section 803.5, Wall and Ceiling Finishes Table, Utility Structures have no
restrictions for finish requirements. Section 803 has no notation that it is superseded by the section
requiring thermal barrier which you have used. No interior finish should be required of my structure.
The NUDURA ESR -2092 Report scope applies to buildings intended for human occupancy and not
to agricultural or outbuildings as is my case. I realize if the occupancy status changes, then the
requirements do also, but there is no intent to use this structure for human occupancy.
Thank you for your reconsideration.
Sincerely,
(Ms.) Marion J. Wells
(970) 625-3464
FROM : m PRESS ink.
DELIVERED VIA FAX
FAX NO. : 970-625-0843 Feb. 07 2011 02:23PM P1
Mr. Fred Jarman, Director
Garfield County Building Sr Planning Department
108 Sth Street, Suite 401
Glenwood Springs, Colorado 81601
RE: Final Inspection at 6702 County Road 309
Dear Mr. Jarman,
6691 County Road 309
Parachute, Colorado 81635
3 February 2011
RECEJVED
FEB 0 7 2011
GARFIELD COUNTY
BUILDING & PLANNING
A recent encounter with Mx. Andy Schwaller of your department has Ieft me concerned. I have a barn, a
separate accessory unit, that was permitted last year. NUDURA ICF's were used for three walls; the fourth is
rammed earth. Upon NUDURA's recommendations, there is no provision in the county -approved barn plans to
finish the interior. When the final inspection was done, a new requirement was added: interior drywall. This
surprised me and represents an unanticipated and substantial cost to the barn.
Knowing that code requirements are based in common sense, I thought it a burdensome requirement. This is a
barn. There is no occupancy issue. The NUDURA product has fire retardant and uses higher construction
standards than most ICFs. NUDURA consulted an ICC Code Adviser who provided the following information.
Section 300 decides requirements based on use and occupancy. A barn/ private garage accessory unit qualifies
under the Utility Group in Section 312. The interior wall finish requirements for the Utility Group under
Section 803 has no restrictions. I also checked with another county who agreed with that assessment. I accept
the fact any other group would require foam plastic to have a thermal barrier and, if the occupancy use
changes its group, then the thermal barrier would be needed in the barn.
Mr. Schwaller's position has been recalcitrant from the start. It is extremely disturbing that others. have
been allowed to leave their foam plastic without a thermal barrier when the above conditions would set it in a
group requiring a thermal barrier. I think it unfair to be held to a different standard. Not only is it not required
in my approved plans, only added at the final inspection, but the above analysis demonstrates it is unnecessary
under existing conditions. However, the county's position appears to be set in stone rather than reason and I
must foot a large added cost to complete ray project.
What becomes truly egregious is Mr. Schwaller's failure to provide the name of his supervisor when asked.
He became officious and beyond reason, ending the conversation by hanging up on me without answering the
question. (1 called back and received the answer from the receptionist.) Mr. Schwaller addressed my issues by
stating he was the only and ultimate authority in this matter. When the issue of fire retardant was raised, he
dismissed it as being a false contention for a hundred years? Such dismissive and unprofessional behavior
should be addressed. I request the certificate of occupancy be issued since the plan requirements have been met.
Sincerely,
yely
(Ms) Marion J. Wells
David Bartholomew
Fi4 ir copy 9-09-/Z 87
Crom: Andy Schwaller
ent: Thursday, December 16, 2010 4:04 PM
To: Matt Provost; David Bartholomew; Jim Wilson
Subject: FW: 03 IRC/IBC R314/803 (JW -12/13)
From: Jeff Walker [mailto:JWalker@iccsafe.org]
Sent: Thursday, December 16, 2010 10:13 AM
To: Lis Valdemarsen
Cc: Andy Schwaller
Subject: RE: 03 IRC/IBC R314/803 (JW -12/13)
Mr. Schwaller,
Thanks for submitting your code opinion questions to ICC. Your questions referenced Section R314 of the 2003 IRC and
Section 803 of the 2003 IBC, and are paraphrased as follows:
Q1: Do insulating concrete forms (ICFs) in IRC accessory structures require a thermal barrier?
Al: Yes.
Section R314.1.2 of the 2003 IRC requires a thermal barrier for all foam plastic installations within an IRC structure,
unless one of the "specific requirements" of Section R314.2 can be met (note that there is NO exception for accessory
structures). If an accessory structure is over 3,000 square feet in floor area, then it would fall under the IBC as a Group U
structure, if allowed in a residential zone by the local authority having jurisdiction.
02: Does IBC Table 803.5 (Group U) waive the requirement for a thermal barrier for insulating concrete forms (ICFs) in
IRC accessory structures?
A2: No.
The accessory structure in question falls under the IRC, NOT the IBC, unless it is over 3,000 square feet in floor area, and
as allowed by the local authority having jurisdiction; then it would be defined as an IBC Group U structure.
For general information, IBC Group U structures with ICF systems are required to comply with Section 2603.4, which are
similar in nature to Section R314.2 of the IRC.
Table 803.5 of the 2003 IBC addresses finishes, NOT insulation; although the material can be considered as a `finish', the
additional requirements for insulation, as well as the additional requirements for foam plastic, must also be met.
Section 803.8 directs insulation requirements to Section 719.
Exception 2 of Section 719.1 defers foam plastic insulation requirements to Chapter 26, and hence, Section 2603.4.
These opinions are based on the information which you have provided. We have made no independent effort to verify the
accuracy of this information nor have we conducted a review beyond the scope of your questions. ICC Staff has no
authority concerning code enforcement; therefore, these opinions are only advisory, and the final decision is the
responsibility of the designated authority charged with the administration and enforcement of this code. These opinions
are solely based on the International Code in question, and do not consider any federal, state, or local amendments,
ordinances or policies which may exceed the minimum requirements as set forth in the International Code referenced.
Sincerely,
Jeff H. Walker, P.E., C.B.O., M.C.P.
Senior Staff Engineer
\rchitectural & Engineering Services
international Code Council
The Intemational Code Council (ICC) Plan Review Services staff of professionals is ready and available to serve your plan review needs. Please
contact the ICC Plan Review Department at 1-888-ICCSAFE (422-7233) extension 33809, or visit the /CC website et:
1
w.4ccsafe.ora/cs/P2aes/PR-Consulting. asox
From: Lis Valdemarsen
Sent: Monday, December 13, 2010 3:59 PM
To: Jeff Walker
Cc: 'aschwaller@garfield-county.com'
Subject: 03 IRC/IBC R314/803 (JW -12/13)
Andy,
I have forwarded your request to Jeff Walker.
If you have any questions regarding the status of your reply to your code opinion question, please contact me by either
phone or email.
Sincerely,
Lis Valdemarsen
Senior Secretary
International Code Council, Inc.
Los Angeles District Office
5360 Workman Mill Rd
Whittier. CA 90601-2298
Phone: (562) 699-0541 ext 3201
Fax (562) 699-4522
Ivaldemarsen@icrsafe. orq
www.iccsafe.orq
Did you know that all ICC National Certification Exams referencing the I -Codes:. will be based on the 2009 I -Codes beginning
January I", 2010? Are you ready? Check out ICC Training to learn about the options ICC has to help you get up to speed
Free Download of Energy Code Available. ICC has been awarded federal funding to provide the 2009 International Energy
Conservation Code as part of an initiative to meet nationwide energy -efficiency goals through the Building Technologies Program and
the American Recovery and Reinvestment Act. Get yours today — click here!
Feed: Codes, Standards & Guidelines: Request Code Opinion
Posted on: Friday, December 10, 2010 1:25 PM
Author: Andrew Schwaller
Subject: Andy Schwaller
Requestor Full Name: Andy Schwaller
Job Title: Building Official
Phone Number: 970-945-8212
Requestor email address: aschwaller@garfield-county.com
Requestor Address: Garfield County Building and Planning 108 8th Street Suite 401 Glenwood Springs, CO
81601
Code Reference: Sec R314 Foam Plastics IRC and Sec 803 Interior Finishes 2003 IBC.
Code Edition: 2003
Code Section: Foam Page 53 IRC and Interior finishes page 177 IBC.
questions: 1. Under the IRC, would Insulating Concrete Forms need a thermal barrier in a detached garage or
hop type of building? 2. Under the IBC Table 803.9 a Group U shows No Resrictions for interior walls. Would
this apply to not requiring a thermal barrier? We have a permit holder that is arguing the point using Question
2
Jve. The permit holder said the ICC provided item 2 as a reason not to provide a thermal barrier on the
in a garage or U occupancy. Thanks, Andy
. Latus: New
View article...
3
Ms. Marion J. Wells
6691 County Road 309
Parachute, CO 81635
February 8, 2011
RE: Building Permit BLRE-9-09-1287
Dear Ms. Wells:
BUILDING & PLANNING DEPARTMENT
This letter is in response to your letter of February 3, 2011. From my conversations with Andy
Schwaller, communication over the phone reached a point of non communication and it was not
productive for either of you to continue. He does apologize for ending the conversation. Possibly, I will
be able to communicate our position better with this letter and thank you for the opportunity to do so.
I asked Andy to review your file and plans associated with your building permit and we have the
following comments. The barn in question was reviewed under the 2003 International Residential Code
(IRC). We also reviewed the 2003 International Building Code (IBC) Group U occupancy for the
requirements related to exposed foam in the interior of a building. In both cases the foam has to be
covered by a thermal barrier. In reviewing the exceptions to the rule under R314.2 of the IRC, we could
not find an exception related to your installation. Under the IRC Section R314.1.2, foam plastics shall be
separated from the interior of a building by a thermal barrier.
In reviewing the commercial code IBC, and Section 803 related to interior finishes you referenced in
your letter, it would appear your argument has some validity and I can understand your confusion with
the code. It is sometimes less than clear. Table 803.5 does exempt your barn from an interior finish but
not from the thermal barrier. Section 803.8 Insulation refers the reader to Section 719 Thermal and
Sound- Insulating Materials. Section 719.1 Exception 2 refers the reader to Chapter 26 Plastic. Section
2603 Foam Plastic Insulation requires the foam plastic to be covered by a thermal barrier with very
similar requirements and exceptions as found in the IRC. There is also a footnote "k" in Table 803.5 that
references the reader to other code sections.
In general, all foam insulation on the inside of a building has to have the thermal barrier. Some
Insulating Concrete Forms (ICF) manufactures have had their products tested by ICC Evaluation Services
and in limited installations in crawlspaces, a thermal or ignition barrier is not required. This type of
application is the only exception to the rule that we allow. You should check with your supplier for any
ICC Product Evaluation Reports.
108 Eighth Street, Suite 401 • Glenwood Springs, CO 81601
(970) 945-8212 • (970) 285-7972 • Fax: (970) 384-3470
Neither I nor Andy is the final word regarding building code interpretations. The Board of Review as per
Section R112 of the IRC is tasked with this. If Andy oversteps the interpretations of the code, the BOR
has the authority to correct him. Andy did check his interpretation with the International Code Council
Technical Services. I will include a copy of their response. It would appear they agree with Andy's
review of the code items and the requirement for a thermal barrier.
I am sorry this aspect of your project has caused you some grief. It would appear you are caught in a
catch 22 with what you were told by NUDURA and what the code actually requires. Please call or e-mail
with any questions you might have.
Yours Truly,
Fred A. Jarman AICP `\
Director
Garfield County Building and Planning
cc Andy Schwaller
encl