Building Code advisory group tables childcare-centers opinion after debate over IEBC vs. IBC placement

The Washington State Building Code Council IBC technical advisory group discussed draft code language and an opinion on how to apply RCW 19.27.600 to childcare centers in existing buildings during its Dec. 4, 2025 meeting, but ultimately withdrew an earlier recommendation and tabled both the opinion and proposed 2024-code language for further work.

The committee opened the item after staff said the petitioner had rescinded a petition for rulemaking in exchange for the council drafting an opinion and code language reflecting the committee’s preferred “option number 3.” Dustin (staff) presented an opinion draft and a revised language proposal, noting the matter relates to "RCW 19 27 600, which, was passed in the 20 24 legislative session" and that original interpretation had been that the statute "wouldn't require any rulemaking." The stated intent of the draft language was to give building and fire officials clarity and to provide retrofit relief for childcare centers moving into existing footprints without requiring full building upgrades.

Technical debate focused on whether the new language should reference specific IBC/fire-code tables for fire-barrier hour ratings or be framed as creating a separate fire area, which then would invoke existing tables. Tim Woodard asked, "what rating do we use?" and whether the proposal should explicitly point to the IBC table; he and others noted that separating a space into its own fire area is already a path that can regulate sprinklers and other systems. Ken (a proponent) and others argued the International Existing Building Code (IEBC) — specifically change-of-occupancy provisions in chapter 10 (10.11) and the prescriptive chapter 5/506 — may be the correct location for language affecting conversions in existing buildings (for example, adding a daycare in a church), because those sections already provide mechanisms for relief and limited upgrades.

Committee members raised additional interpretive concerns: whether the proposed requirement to add a fire barrier would be overly broad in buildings that are already fully sprinkled, whether the proposal should instead reduce a table’s required rating (for example, 2-hour to 1-hour) to facilitate retrofits, and how to ensure consistent application across IEBC chapters that govern both work-area and prescriptive compliance paths. Gordon Hicks with the Seattle Department of Construction and Inspections urged cross-references to both chapter 10 and the prescriptive chapter(s) so changes apply in all relevant IEBC methods.

Procedurally, Tim Woodard moved to approve the opinion and recommend it to the Building and Fire Related Work (BFRW) committee "with those modifications," Josh Merrigan seconded, and the chair recorded the motion as recommended to the BFRW. Later in the meeting, however, members agreed they needed more technical clarity before forwarding anything. The group withdrew the earlier approval of the opinion and voted to table both the opinion and the proposed 2024 code language to a later meeting for further drafting and coordination with staff.

Next steps: staff will redraft language to address the committee’s technical concerns (table references, where the language should sit in the codes, and cross-chapter consistency) and return the item for further discussion; the committee scheduled follow-up outreach and additional review in advance of the next meetings.