What you need to know about the latest California code updates

By Steven Dannaway, PE | Principal, Operations Manager

California will adopt the Intervening Supplement to the 2022 California Building Code (CBC) on July 1, 2024. This article examines one of the significant changes, which eliminates Group I-2.1 occupancies.


California had amended the International Building Code (IBC) to create a California-specific occupancy, Group I-2.1, which applied to outpatient facilities where six or more patients were rendered incapable of self-preservation based on the treatment received. Outpatient ambulatory surgery centers (ASCs) were one example of a common Group I-2.1 occupancy.

Code Change

California will be eliminating the Group I-2.1 occupancy classification. This code change will align the CBC closer with the requirements of the model code, the IBC, and NFPA 101.  Outpatient facilities with occupants considered incapable of self-preservation will now be Group B ambulatory occupancies, subject to the requirements of CBC Section 422. NFPA 101, Chapter 20 requirements will also still apply (Ambulatory Health Care occupancies). As part of the Intervening Supplement, California introduced code amendments that carry forward select Group I-2.1 requirements that will now apply to Group B ambulatory occupancies.

Significant impacts from this change include:

  • Occupancy classification of outpatient ambulatory health care facilities will be Group B. Special ambulatory care facility requirements of CBC Section 422 will apply.
  • This change does not impact whether a facility is subject to OSHPD-3 classification.
  • Allowable height, allowable area, and type of construction are now based on a Group B occupancy. Group I-2.1 allowable height/area limits aligned with Group I-2 hospitals, which are stringent and pushed Medical Office Buildings (MOBs) into a more restrictive type of construction. This change allows MOBs to be built to larger sizes with less restrictive fire-resistance ratings.
  • Corridors can be non-rated in fully sprinklered Group B ambulatory care occupancies.
  • Waiting areas and other spaces can now be open to the corridor without additional restrictions.
  • Corridor width is still governed by CBC Table 1020.3 and CBC 1224.7. Corridors accommodating the day-to-day movement of beds/gurneys require a 96-inch corridor width per CBC 1224.7.1.  Other corridors that only serve as required exits from floor areas with beds/gurneys require a 72-inch corridor width per CBC 1020.3.
  • Door width is still a minimum 44-inches clear width for required egress doors serving areas with bed/gurney patients per CBC 1010.1.1.
  • Smoke compartments are required when the ambulatory care facility exceeds 10,000 sf.
  • Exit access travel distance to an exit is limited to 200 ft.
  • The ambulatory care facility must be separated by minimum 1-hour fire barriers and/or horizontal assemblies for other building areas. This would be similar to an occupancy separation or care suite separation in Group I-2 occupancies.
  • Incidental use spaces such as storage rooms > 100 ft or soiled utility rooms still require fire separation per CBC Table 509.1.
  • Two-story vertical openings and unenclosed exit access stairways are permitted in Group B ambulatory care occupancies. Two-story vertical openings were stringently regulated under a Group I-2.1 occupancy.

This article summarizes the significant impacts of the new California code changes to eliminate Group I-2.1 occupancies. Means of egress requirements generally remain the same; however, this code change provides designers with increased flexibility associated with building height and area, type of construction, non-rated corridors, and two-story vertical openings connecting multiple stories.

For more information, contact Steven Dannaway, PE.