Issue: DCA-DEC-351 by Joe Belcher.  The Petitioner is requesting clarification regarding the prospective application of Section 102.1 and 102.4 as they relate to the installation of receptacle outlet in Category 1, II, and III sunrooms as specified by the Florida Building Code and AAMA 2100.  Specifically, the Petitioner provides for the following question:

 

Question:  In the case of sunrooms attached to single family dwellings, do the provisions of AAMA 2100 related to receptacle outlets prevail?

 

Background:

 

(1)        Description of situation:

 

The Aluminum Association of Florida (AAF) is an organization of contractors specializing in the construction of aluminum structures. AAF has an interest in this issue because a number of AAF members sell and build sunrooms in Florida. AAF is requesting the petition on behalf of Gary Whigham, an AAF member. Mr. Whigham is in the process of planning for a project to attach a sunroom to a single family dwelling and has noted the differences between NFPA 70 and AAMA 2100 and believes there may be room for differing interpretations. 

 

(2)        2007 Florida Building Code, Residential

 

301.2.1.1.2 Sunrooms. Sunrooms shall comply with AAMA/NPEA/NSA 2100 with the structural requirements and testing provisions of Chapter 5 modified to incorporate ASCE 7. Sunrooms shall be categorized in one of the following categories by the permit applicant, design professional or the property owner where the sunroom is being constructed.

 

Category I: A roof or a covering of an outdoor space. The openings shall be permitted to be enclosed with insect screening or 0.5 mm (20 mil) maximum thickness plastic film. The space is defined as nonhabitable and unconditioned.

 

Category II: A roof or a covering of an outdoor space with enclosed walls. The openings are permitted to be enclosed with translucent or transparent plastic or glass. The space is defined as nonhabitable and uunconditioned.

 

Category III: A roof or a covering of an outdoor space with enclosed walls. The openings are permitted to be enclosed with translucent or transparent plastic or glass. The sunroom complies with additional requirements for forced-entry resistance, air-leakage resistance and water-penetration resistance. The space is defined as nonhabitable and unconditioned.

 

Category IV: A roof or a covering of an outdoor space with enclosed walls. The sunroom is designed to be heated and/or cooled by a separate temperature control or system and is thermally isolated from the primary structure. The sunroom complies with additional requirements for forced-entry resistance, water penetration resistance, air-leakage resistance, and thermal performance. The space is defined as habitable and conditioned.

 

Category V: A roof or a covering of an outdoor space with enclosed walls. The sunroom is designed to be heated and/or cooled and is open to the main structure. The sunroom complies with additional requirements for forced-entry resistance, water-penetration resistance, air-leakage resistance, and thermal performance. The space is defines as habitable and conditioned.

 

(3)        E3301.1 Applicability. The provisions of NFPA 70, National Electrical Code Requirements shall establish the general scope of the electrical system and equipment requirements of this code.

 

2008 NFPA 70:

 

 

 

(4) AMA/NPEA/NSA 2100, 2002:

 

7.7 Electrical

7.7.1 Exit and Stairway Illumination: All sunrooms shall provide stairway and egress illumination as required by local code.

Exception: Category I sunrooms are not required to have exit lighting.

7.7.2 Receptacle Outlets: Receptacle outlets in Category IV and V sunrooms must be installed such that no space along a wall line is in excess of 1.8 m (6 ft.) from a receptacle outlet. Any wall space that is 610 mm (24 in.) or wider must be served by a receptacle outlet in this manner. Fixed panels of sliding doors are not considered wall line. Where the installation of a typical wall receptacle outlet is not possible, a floor receptacle installed within 460 mm (18 in.) of the wall line may be installed to serve this space.

Exception: Category I, II and III sunrooms are exempt from requirements for receptacle outlets."

 

(5)        2007 Florida Building Code, Building:

 

102.1 General. Where, in any specific case, different sections of this code specify different materials, methods of construction or other requirements, the most restrictive shall govern. Where there is a conflict between a general requirement and a specific requirement, the specific requirement shall be applicable.

 

102.4 Referenced codes and standards. The codes and standards referenced in this code shall be considered part of the requirements of this code to the prescribed extent of each such reference. Where differences occur between provisions of this code and referenced codes and standards, the provisions of this code shall apply.

 

(6)  See below for BOAF Informal Interpretation on the subject.

 

(7)        With regard to the subject in question, the FBC, Residential (the Code) adopts by reference two standards: (1) NFPA 70 and (2) AAMA 2100.  NFPA 70 provides for the electrical requirements for electrical systems covered by the FBC including sunrooms.  However, for the specific design and construction of sunrooms, the Code adopted AAMA 2100.   AAMA 2100 is more specific than NFPA 70 with regard to definition of the term “sunroom”, the categories of sunrooms and the placement of the receptacle outlets within each category of sunrooms.  Therefore, in according with Section 102.1, the specific requirements of AAMA 2100 with regard of placement of receptacle in sunrooms prevail over those of the NFPA 70. 

 

Staff recommendation:

 

Question:           In the case of sunrooms attached to single family dwellings, do the provisions of AAMA 2100 related to receptacle outlets prevail?

 

Answer:            Yes.  AAMA 2100 is more specific than NFPA 70 with regard to the definition of sunrooms and the placement of receptacle outlets, and therefore in according to Section 102.1 of the FBC, Building, and AAMA 2100’s provisions prevail over NFPA 70 with regard to the subject in question.