BCAB #1270 - Combustible Millwork in Noncombustible Construction, Clauses 126.96.36.199.(3)(a), 188.8.131.52.(3)(g) and 184.108.40.206.(3)(h)
January 15, 1992
Re: Combustible Millwork in Noncombustible Construction, Clauses 220.127.116.11.(3)(a), 18.104.22.168.(3)(g) and 22.214.171.124.(3)(h)
The project is a fully sprinklered four storey hotel of noncombustible construction. Foamed plastic trim mouldings are proposed at the wall/ceiling intersection in hotel rooms/suites. These mouldings will be covered by acrylic stucco.
Reason for Appeal
Clause 126.96.36.199.(3)(a) permits combustible millwork in buildings of noncombustible construction but Clauses 188.8.131.52.(g) & 184.108.40.206.(h) do not permit foamed plastics as wall or ceiling finishes.
The appellant feels that although millwork has been traditionally made of wood the Code does not stipulate the type of combustible material in Clause 220.127.116.11.(3)(a) so foamed plastic should be acceptable. He further maintains that it should not be subject to Clauses 18.104.22.168.(3)(g) & (h) because they deal with wall and ceiling finishes, not millwork, which has been singled out by Clause (a). The appellant has provided a detailed rationale to support his contention that the Code permits foamed plastic millwork.
Building Official's Position
The building official maintains that although combustible millwork is permitted by Clause (a) of Sentence 22.214.171.124.(3) the same Sentence, in Clauses (g) and (h), restricts wall and ceiling finishes to materials other than foamed plastic. He points out that Sentence 126.96.36.199(1) indicates trim is considered to be part of interior finishes. He contends that allowing the permissive clause, 188.8.131.52.(3)(a), to override the restrictive Clauses, 184.108.40.206.(3)(g) & (h), in the same Sentence would defeat the Code's intent of establishing minimum requirements.
The building official also refers to Sentence 220.127.116.11(2) which requires substantial protection of foamed plastic in combustible construction. He maintains that it would be inconsistent to require less protection of foamed plastic in noncombustible construction than in combustible construction.
Appeal Board Decision #1270
It is the interpretation of the Board that the foamed plastic in question is part of the wall or ceiling finish under Clauses 18.104.22.168.(3)(g) & (h). These Clauses prohibit foamed plastics as part of the interior wall or ceiling finish. The Board considers the foamed plastic trim and its acrylic stucco covering to constitute the interior finish. Therefore, it is the determination of the Board that acrylic stucco covered foamed plastic is not permitted as part of the interior finish in buildings of noncombustible construction.
George R. Humphrey, Chair