Shortly after 5 PM on October 17, 2003, a small fire started in a supply room on the 12th floor of the 35- story Cook County Administration Building at 69 West Washington Street in Chicago’s Downtown Loop, which was constructed in 1964 and only partially sprinklered. The un-sprinklered 12th floor supply room was adjacent to one of the two stairwells in the building that employees could use to evacuate during emergencies. Responding to the fire with 135 firefighters and paramedics and 45 pieces of equipment, the Chicago Fire Department successfully contained and extinguished the fire.
After the fire was contained, however, firefighters found the bodies of thirteen workers who did not make it to safety. Fire department personnel revived seven of the victims, but the remaining six suffocated in the stairwell.
The Catalyst for the LSE in Chicago
Following the devastating fire, Chicago formed the High-Rise Safety Commission. While the city had updated its building code in 1975 to require strict compartmentation or sprinkler systems in new high-rise construction, hundreds of older high-rises, like 69 W. Washington, fell under grandfathered provisions. The Chicago Life Safety Evaluation (LSE) originated in 2004 to bring older, pre-1975 high-rise buildings up to acceptable fire-safety standards. However, instead of mandating prohibitively expensive retrofitted fire sprinklers in all existing residential or historic high-rises, the city created the LSE as an alternative to assess overall fire safety and occupant protection. The Commission developed the LSE to establish an equivalent level of safety for these older structures without forcing total sprinkler retrofits. More than 700 high-rises were evaluated under this process between 2005 and 2017, the legally mandated deadline. Most of these buildings were allowed to remain unprotected with sprinklers.
Core Principles of the Evaluation
The LSE assessed the building's features and assigned a numerical score based on the following specific criteria:
- Fire Safety: Evaluated passive fire containment (e.g., fire-rated corridor walls and stairway doors) and active measures like standpipe systems.
- Means of Egress: Measured the ability of occupants to safely escape, focusing on exit travel distances and evacuation routes.
- Communications: Mandated the installation of one-way or two-way voice communication systems to allow the fire department to communicate with building occupants during an emergency.
Regulatory Process and Enforcement
- Mandated Compliance: The ordinance required building owners to hire a licensed architect or engineer to perform, sign, and seal the evaluation.
- Minimum Scores: Buildings that achieved the minimum required LSE score were certified as having an acceptable life safety compliance plan.
- Retrofits: If a building failed the evaluation, owners were legally required to either upgrade features (like fire-rated doors and communication systems) or install automatic sprinklers to achieve a passing score.
Chapter 13 of the International Existing Building Code (IEBC), adopted for Chicago in 2019 as the Chicago Building Rehabilitation Code, provides a Performance Compliance Method (PeCM), allowing any older, existing building undergoing substantial alterations or major changes of occupancy (other than High-Hazard Group H or Institutional Group I-1, I-3, or I-4) to be evaluated using a numerical scoring system like the one previously used for the LSEs. This version evaluates 19 distinct life safety parameters against a minimum accepted score, ensuring the building achieves an acceptable level of safety without requiring full, cost-prohibitive compliance with new construction codes.
How the Evaluation Works
The evaluation process is broken down into three mandatory safety categories:
- Fire Safety: Assesses structural fire resistance, automatic detection, alarms, and suppression systems.
- Means of Egress: Evaluates the layout, capacity, and supporting features of your escape routes.
- General Safety: A combination of fire safety and egress elements, typically derived by analyzing both.
Step-by-Step Methodology
- Determine Occupancy and Construction Type: Identify the exact occupancy group (e.g., Business, Mercantile, Assembly) and the building's type of construction.
- Score the 19 Parameters: For each parameter (such as building height, vertical openings, corridor walls, and sprinkler systems), you assign a positive, negative, or zero-point value based on the tables in Chapter 13.
- Calculate the Total: Tally the parameter values for each of the three safety categories.
- Compare to Mandatory Scores: Cross-reference your results with the mandatory safety score tables provided in the code. If your score equals or exceeds the mandatory score for each category, the building is deemed code compliant.
Key Considerations
- Structural Analysis Required: While this evaluates fire and life safety numerically, you must still perform a structural analysis demonstrating the building can withstand the full wind and seismic loads required by the International Building Code (IBC Chapter 16).
- Safety Can Never Decrease: A baseline rule of the code is that no alterations can leave the existing building less safe than it was prior to the proposed new work.
- Utilize Existing Tools: Design professionals can reference the interactive, searchable spreadsheet tools online (ICC, UpCodes) to map out numerical scoring scenarios and determine compliance passing grades.
The Safety Parameters
The overall safety of a building is dependent on factors such as the ability of the occupants to exit, to receive warning alarms, and to have adequate time to escape in the event of an emergency. These factors are given numerical values, which in turn are incorporated into total building scores which indicate whether the conditions meet the minimum requirements to be deemed acceptable.
Note that several of the 19 safety parameters are weighted more heavily by larger point values. This could be viewed as a drawback or as an opportunity. Negative scores can be overcome with architectural modifications to another parameter, such as constructing fire barriers or the replacement of non-compliant features like non-labeled doors in fire-rated walls. Building owners are often surprised by how many compliant alternatives exist when presented with alternative solutions that achieve passing scores without them.
Completing the PeCM – and Beyond
The evaluation process is completed using the formulas found in Table 1301.7. The total building scores must then be entered for each of the three categories onto a Summary Sheet and then compared with the Mandatory Safety Scores in the code. If the difference between the corresponding numbers is zero or positive in all three Safety Categories, the building passes and the analysis is complete. Whatever alterations that were determined to be necessary to achieve the passing scores would then need to be made.
By no means, however, is this the end of the story. Buildings continuously adapt and change over time. As alterations and modifications to a building are proposed after an initial evaluation has been done, it is important to verify whether the proposed changes are in alignment with the PeCM, since those changes may affect a previously passing score and send it into negative territory.
How do you know whether a newly proposed alteration is in conformance with or will undermine the previously established Safety Parameters? The only way to know this is to review the original evaluation. If you were not the original author of the evaluation, you must rely on being able to retain a copy from the building owner or the jurisdictional authority that received, inspected and approved it. Maintaining that initial data becomes a crucial element of any redesign moving forward.
The Architect as a Data Steward
This is what some might call Enhanced Due Diligence. The architects who position themselves as a building’s data steward — the institutional memory of what was previously built, why, and how it should evolve — is closer to what was once termed ‘master builder’ than any in the profession have been in generations.
Burnham Can Help
Amenity retrofits are one of the most code-complex project types in commercial real estate right now. Occupancy reclassifications, egress recalculations, accessibility triggers, variance negotiations. These aren't surprises if you bring the right team in early.
Burnham Nationwide specializes in permit expediting and code consulting for exactly these situations. We know how to read an existing building against current code requirements, identify where the conflicts are, and work with local building officials to find a path forward before those conflicts become budget problems.
If you're planning an amenity addition or office retrofit, let's talk before the design gets too far along. That's where we do our best work.
