Finger Lakes Building Officials, Inc.

An Affiliated Member of the New York State Building Officials Conference

October 26, 2003

This letter is in response to your question regarding the Building Code of New York State, 2002 edition (BCNYS)[19 NYCRR 1221.1].

Question:
What would the appropriate use group classification be for an interior loading area that has loading docks and refuse compactors?

Background:
A 3 story, unlimited area type 1B, with a theater and various mercantile occupancies. The building is fully sprinklered .The area in question is used for the exchange of commerce between trucks and the occupancies within the building.

Opinion:
It is our opinion that this area is most suitably classified as a use group S-1. The regular storage of combustible materials, such as cardboard, clothing, and other commodities most closely meets the intent of use group S-1. Even though the BCNYS would consider tractor-trailer trucks and compactors non-combustible, the hazard within the such containers would raise the hazard level to moderate.

The use of non-combustible, according to the International Building Code Commentary, speaks of non-combustible being a non-combustible product that is covered or layered with one layer of combustible material. Examples are glass bottles in cardboard boxes or crating that contains processed metals.

Since the description of incidental use areas are based on the main occupancy per BCNYS 302.1.1, the subject interior loading area cannot be considered incidental since it doesn't just serve a main occupancy but several different occupancies.

This advisory opinion is rendered based upon the information provided. Administration and enforcement of the code are within the jurisdiction of the local authority. If you have any questions or wish to discuss this matter further, please call me at (518) 474-4073.

Sincerely,
Daniel E. Nichols
Fire Protection Engineer I
Division of Code Enforcement and Administration
Al03-225

Finger Lakes Building Officials Association, Inc.
3100 Atlantic Ave.
Penfield, NY 14526