2018 I-Codes—Residential Rooftop Access

2015 Vs. 2018 Access & Egress Requirements
IFC Section 1204.3 provides an exception that extends Group R-3 residential requirements to non-Group R-3 buildings when the roof configuration is similar.

The 2018 International Residential Code and International Fire Code (the IRC and IFC, two of the I-Codes) have been published, and PV system designers and installers should be champing at the bit for their local authorities having jurisdiction (AHJs) to adopt them, as there are significant beneficial changes regarding firefighter access requirements for residential rooftop PV systems. (View the I-Codes online at codes.iccsafe.org.)

Like the National Electrical Code (NEC), the I-Codes are updated on a three-year cycle. They first substantively addressed PV system installation requirements in the 2012 editions. Currently, the I-Codes detail requirements for marking PV systems, particularly for labeling rapid shutdown systems. These requirements match those of the 2017 NEC. The labeling provides crucial information for first responders and firefighters. The IRC also addresses PV equipment listings, roof and wind loading, fire classification, roof penetrations, and building-integrated PV.

The 2012 and 2015 I-Codes editions contained many detailed requirements regarding the installation of the electrical equipment associated with PV systems—but the language was not always consistent with the NEC. The 2018 IFC and IRC defer to the NEC, stating that the “electrical portion of solar PV systems shall be installed in accordance with NFPA 70” (IFC 1204.1 and IRC 324.3).

Access & Pathways

Regarding residential rooftop PV systems, the I-Codes’ primary focus is to ensure safe and adequate access—and egress—so that fire-fighting operations are not interrupted or hindered. This is accomplished through requirements for:

  • Access for inspection
  • Pathways with structural support and minimal obstructions (including conduit, vents, and other equipment) that are capable of supporting firefighters
  • Adequate spacing for ventilation opportunities
  • Roof egress

The access and pathway requirements, found in IRC Section R324.6 and IFC Section 1204.2, apply to “Residential Group R-3” occupancies with roof pitches greater than 2:12, defined in Section 310.4 of the International Building Code (IBC). These include one- and two-family dwellings; care facilities with accommodations for five or fewer people; congregate living facilities with 16 or fewer nontransient occupants (such as convents, dormitories, fraternities/sororities, and monasteries); boarding houses with 10 or fewer transient occupants; and transient lodging houses with five or fewer guest rooms and 10 or fewer occupants. Note that IFC Section 1204.2.1 also defers to the IRC, stating that the IFC rules do not apply to Group R-3 buildings constructed in accordance with the IRC (the requirements in the two I-Codes being essentially the same).

The Old…

Many PV system designers and installers are familiar with the more stringent access requirements in earlier editions of the I-Codes. These requirements ate into precious rooftop area, the lack of which is often a limiting factor in a PV system’s size. These restrictions called for:

  • 36-inch-wide pathways from the ridge to the drip edge, along both edges of the roof surface
  • Array setbacks at least 36 inches from the ridge
  • At least 18 inches of space on either side of a hip or valley

But the requirement that very much limited potential system size was the one that specified each roof surface with PV had to be treated independently, so the pathways had to be provided for every individual roof surface with PV mounted on it.

Comments (2)

Alberto Marty's picture

Will this apply to the solid reinforced concrete roof at home?

Anthony Maciorski's picture

At what pitch would be too steep for fire fighters to step on?

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