Insights topic · 2 articles
Code Strategy
Using alternative methods, variances and equivalencies for existing buildings, changes of occupancy and performance-based design.
When a project cannot meet the code as written, there is usually an approved way forward: an alternative method under IBC 104.11, a variance or modification, or a performance-based design. Existing buildings and changes of occupancy add their own rules. The guides below explain each path and what makes a request approvable.
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What Fire Protection Does a Change of Occupancy Trigger?
A change of occupancy triggers sprinklers, fire alarm and egress upgrades wherever the code requires them for the new use. How the IEBC hazard comparison works, what PA, NJ, NYC,…
Questions this topic answers
What it is
| Question | Code basis | Last reviewed |
|---|---|---|
| What Is IBC 104.11? Alternative Methods and the NYC CCD1 | IBC 104.11 (2021), 104.2.3 (2024); NYC Admin. Code 28-103.3 and CCD1; N.J.A.C. 5:23-2.10; 34 Pa. Code 403.122; 19 NYCRR Part 1205; Maryland Building Performance Standards; Delaware Regulation 701 and county IBC adoptions | Oct 2026 |
When it is required
| Question | Code basis | Last reviewed |
|---|---|---|
| What Fire Protection Does a Change of Occupancy Trigger? | IEBC Ch. 10 Section 1011 (2021); N.J.A.C. 5:23-6.31; NYC Admin. Code 28-102.4.2 and Local Laws 33 and 42 of 2026; Existing Building Code of NYS (2025 Uniform Code); Delaware county IEBC and NFPA 101 (2024); IBC Table 1004.5 | Oct 2026 |
From the project portfolio
Sprinkler retrofit for a historic building conversion
- Ornate plaster ceilings
- Concealed heads
- Historical commission
Result: Sprinklered with no visible piping in any restored room.
Read the project story Hospitality · Philadelphia, PASmoke control review for a hotel atrium
- 9-story atrium
- Mechanical exhaust
- CFD modeling
Result: The exhaust fans came in a third smaller than the first estimate.
Read the project story Historic Renovation · Manhattan, NYPerformance-based fire protection for a landmark building conversion
- Landmarked facade
- Office to residential
- Performance-based design
Result: Approved without touching the landmarked facade.
Read the project storyOther topics
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- Life Safety and Egress1 article
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- Approvals by Jurisdiction62 articles
- Working with a Fire Protection Engineer1 article
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DGA Fire Protection Engineering works on these questions every week for owners, architects and contractors in New York, New Jersey, Pennsylvania, Maryland and Delaware.
