On Nov. 6, the State Building Code Council’s IEBC Technical Advisory Group met to continue drafting guidance for temporary emergency shelters and agreed to advance a package of model provisions based on Seattle and Shoreline policies that would allow existing buildings to operate as interim shelters under a fire operational permit.

The draft under discussion would allow "an interim use emergency shelter in an existing building with an operational permit from the Shoreline Fire Department," providing relief from a full change-of-occupancy process while keeping the building’s existing certificate of occupancy, Ardel Jala, building official for the City of Seattle, told the committee.

Why it matters: jurisdictions nationwide are using a mix of hotels, faith‑based facilities and rapidly deployable units such as pallet shelters and tiny‑house villages to provide shelter during cold weather, disasters and as transitional housing. The advisory group’s work is intended to give jurisdictions a clear, statewide model so local building and fire officials can permit and inspect such uses while maintaining life‑safety protections.

Key provisions discussed

- Scope and permit: Shoreline’s approach uses a fire operational permit for temporary use and explicitly states the temporary shelter will not alter the building’s certificate of occupancy so long as permit conditions are met.

- Egress and location: inspectors would look for two egress paths from sleeping areas where feasible; the guidance favors locating shelter sleeping areas within one level of the ground floor to minimize travel distance, requires exit lighting and signage, and prohibits locking required exit paths.

- Emergency systems: the draft calls for interconnected smoke alarms and carbon‑monoxide detectors, portable fire extinguishers, and a posted fire safety and emergency plan in lieu of requiring full sprinkler or fire‑alarm systems in every circumstance.

- Staffing and fire watch: a staffing metric was proposed — one awake, alert adult for every 25 beds — and an operator fire‑watch log with interior walkthroughs at approximately 30‑minute intervals.

- Cooking and hazardous operations: commercial cooking during sleeping hours would be limited; warming ovens or residential stoves were noted as lower‑risk alternatives.

- Accessibility and disability accommodations: the draft would require reasonable accommodation, with the option to place individuals with special accessibility needs at alternate fully accessible facilities when the interim site lacks the necessary features.

- Limits on retrofit requirements: the draft explicitly contemplates relief from full change‑of‑occupancy requirements for temporary use, so mechanical/HVAC, energy‑code envelope work, and full sprinkler retrofit would not be universally required for interim permits.

Debate on duration and tiers

Committee members debated whether to adopt a fixed duration for temporary use or to allow AHJ (authority having jurisdiction) discretion. Existing code definitions commonly treat "temporary" as 180 days or less; members noted Shoreline and Seattle have used variable periods and increments (examples discussed included 180 days, 6‑month increments, or extensions tied to an operational permit). Ray Alshaus, building official for the City of Shoreline, said the permit model allowed Shoreline to deploy shelters without penalizing building owners or changing the permanent certificate of occupancy: "By doing this, we said this won't affect that certificate because this is a temporary use."

Several members recommended tiering requirements by bed count and by the immediacy of the event — for example, different standards for an immediate seismic disaster versus a seasonal extreme‑weather response. Local practice discussed in the meeting included thresholds of about 20 beds (small shelters), 50 beds (limited/seasonal use), and up to 100 beds for larger interim shelters; shelters above 100 occupants were described as generally requiring a full change of occupancy or more extensive retrofits.

Sanitation and health‑code questions

A committee member flagged plumbing‑fixture requirements and public‑health code obligations. The group discussed common field practices — trailer‑mounted fixtures or serviced portable toilets/showers — and whether the legislative exemption language (referenced in the meeting as Senate Bill 5553) permits relief for sanitation elements that would otherwise be required for residential sleeping occupancies. Participants said those decisions are often handled by the AHJ in coordination with public‑health authorities and that the Shoreline approach leaves fixture relief and maintenance to local inspection and service arrangements.

Pallet shelters and tiny‑house villages

Representatives of pallet shelter providers described two common uses: longer‑term transitional villages to address homelessness (speaker cited an average residence time of roughly nine months) and rapid emergency deployments after disasters (hurricane/earthquake), where speed of placement and minimal site utility work are essential. Participants agreed pallet/tiny‑house villages raise additional issues — utility hookups, ADA ramps, and jurisdictional manufacturing/inspection questions involving Labor & Industries — and recommended a separate, dedicated discussion.

Code placement and next steps

Several members recommended publishing the guidance as an IBC appendix (or a structured appendix/chapter hybrid) so jurisdictions can adopt it consistently; an appendix also preserves a clear organization (definitions, occupancy, egress, fire protection, accessibility) while allowing AHJ discretion. The TAG asked staff to convert the current draft guidance into code text for review (appendix or chapter language), to include cross‑references to IFC/operational‑permit provisions, and to invite Labor & Industries and shelter‑provider stakeholders for the next substantive session.

Direct quotes

"This allows for an interim use emergency shelter in an existing building with an operational permit from the Shoreline Fire Department," Ardel Jala said, summarizing the policy uploaded to the TAG meeting materials.

"By doing this, we said this won't affect that certificate because this is a temporary use," Ray Alshaus said, describing Shoreline's use of a fire operational permit to protect building owners from permanent change‑of‑occupancy penalties.

"Typically, our villages have been used to address homelessness ... and the second would be very quick emergency response for something like Cascadia earthquake," Aaron Scott of Pallet Shelters said, describing two deployment models and noting average resident durations.

What the TAG asked staff to do

- Draft model code language (appendix or chapter format) that incorporates the technical provisions discussed and provides an explicit role for AHJ discretion and alternative submittals.
- Return with a focused session on pallet/tiny‑house villages and invite Labor & Industries (L&I) and shelter providers to that meeting.
- Include plumbing/sanitation and public‑health cross‑references in the next draft.

Limitations and open items

The committee did not set a single statewide time limit for interim use; members left open whether a specific duration should be codified or whether the AHJ should retain authority to approve extensions. Vote counts on agenda and minutes approvals were recorded by voice; no numerical tallies for those voice votes were specified in the transcript. The TAG also signaled that the pallet/tiny‑house topic requires a separate, dedicated meeting.

Next meeting: staff to circulate draft code language and stakeholder invitations; TAG to schedule a follow‑up discussion focused on pallet and village shelters.