Exploring complex hotels, resorts, and casinos: Codes and standards

Casinos and resorts are designed for fun and relaxation, but with such projects becoming increasingly complex and high-tech, engineers charged with tackling these structures have challenging work ahead of them in regards to complying with codes and standards.
By Consulting-Specifying Engineer May 18, 2018


Brant Dillon, Matt Dolan, Jeffrey S. Grove, Ronald R. Regan, Mark Richter, Gregory K. Shino, Toby WhiteBrant Dillon, Director of MEP, Mortenson Construction, Minneapolis
Matt Dolan, PE, LEED AP, Senior Design Engineer, Southland Industries, Las Vegas
Jeffrey S. Grove, PE, Director, JENSEN HUGHES, Las Vegas
Ronald R. Regan, PE, Principal, Triad Consulting Engineers Inc., Morris Plains, N.J.
Mark Richter, PE, LEED AP, Partner, National Residential & Hospitality Practice Leader, AKF Group LLC, New York City
Gregory K. Shino, PE, Technical Director of Fire Protection Engineering, NV5, Las Vegas
Toby White, PE, LEED AP, Associate, Sr. Fire Engineer, Arup, Boston

CityCenter, located in Las Vegas, is a mixed-used development totaling 17 million sq ft stretching out over six high-rise towers. Courtesy: JENSEN HUGHESCSE: Please explain some of the codes, standards, and guidelines you commonly use during the design process. Which codes/standards should engineers be most aware of?

Grove: The majority of the United States uses various editions of the family of codes developed by the International Code Council (ICC). These include the International Building Code (IBC), International Fire Code (IFC), International Mechanical Code (IMC), International Plumbing Code (IPC), etc. The IBC and IFC reference a wide variety of standards developed by different organizations, such as the NFPA, ASTM International, American National Standards Institute (ANSI), etc. For example, NFPA has various fire and life safety installation standards, such as NFPA 13: Standard for the Installation of Sprinkler Systems, NFPA 72: National Fire Alarm and Signaling Code, NFPA 14: Standard for the Installation of Standpipe and Hose Systems, and NFPA 20: Standard for the Installation of Stationary Pumps for Fire Protection, to name a few.

Regan: The IBC is the primary code, followed by  NFPA 101: Life Safety Code and NFPA 70: National Electrical Code. Most recent designs have included a resiliency requirement as set forth by the National Infrastructure Advisory Council in 2009. This requirement is most often seen in coastal and Caribbean locations that have experienced massive natural disasters warranting the requirement. LEED certification is a requirement in nearly all domestic and offshore requests.

CityCenter features include a 2,000-seat theater, a 150,000-sq-ft casino, an ultra-high-end retail and entertainment district, an underground parking garage, and a convention center. Courtesy: JENSEN HUGHESWhite: The IBC is the main code in the United States. Users need to be aware of the specific edition adopted in their particular jurisdiction, as well as any and all amendments to the IBC. Many additional codes and standards are referenced directly in the IBC and form an integral part of the overall governing code. NFPA standards are commonly adopted in part or in whole to supplement the IBC requirements. Furthermore, ANSI, ASTM, and the American Society of Mechanical Engineers (ASME) are commonly recognized testing authorities that govern quality and compliance of products of construction.

Dolan: Current codes include the 2012 IBC and associated mechanical/plumbing (IMC and IPC) and energy codes (International Energy Conservation Code (IECC), Uniform Mechanical Code (UMC), Uniform Plumbing Code (UPC), ASME 17.1: Safety Code for Elevators and Escalators , ASHRAE 62.1: Ventilation for Acceptable Indoor Air Quality, and ASHRAE 90.1: Energy Standard for Buildings Except Low-Rise Residential Buildings. The mechanical and plumbing codes generally alternate between the Uniform or International codes depending on the AHJ, unless a specific state code has been adopted. For projects in other countries, such as Macau, we typically use the International codes (IBC, IMC, and IPC) with the addition of local requirements where applicable, such as in life safety systems or building construction with refuge floors. Related NFPA sections are also used as part of the above codes, including 90A/B, 92, and 101.

Shino: The most common codes for fire protection engineers is the IBC and IFC, which also typically adopt NFPA guidelines for installation of fire protection and life safety. Typically, the IBC and IFC define when specific systems are required and the NFPA standards describe how to install the systems.

CSE: What are some best practices to ensure that such buildings meet and exceed codes and standards?

White: Developing a comprehensive fire and life safety strategy for the project is an important first step. Some jurisdictions, such as Clark County in Nevada, require a fire protection report to be stamped by a registered fire protection engineer. In jurisdictions where this isn’t mandatory, most clients voluntarily require it to clearly inform the entire design team of the building’s approach to code compliance. In buildings as complex as fully integrated resorts, it is a logical first step to ensure all consultants and designers are meeting code and designing toward a common solution. Exceeding code is often an owner-driven decision, whether to meet their corporate level of safety or to satisfy a particular underwriter. The fire and life safety strategy report would document such enhancements and become a contract document that is followed by the building and system designers. Traditionally, where specific directions to exceed code is not written into the contract documents, designers would not normally exceed code minimum as this incurs costs and possibly increased complexity.

CityCenter features include a 2,000-seat theater, a 150,000-sq-ft casino, an ultra-high-end retail and entertainment district, an underground parking garage, and a convention center. Courtesy: JENSEN HUGHESShino: Probably the most important thing to consider is staying ahead of the curve by participating, or at least following, the codes and standards development process. Knowing what AHJs around the country and world are facing in terms of code enforcement, helps shape how codes are developed. New building technologies, such as cross-laminated timber building materials, are advancing the construction industry, but codes and standards must keep up to make sure building occupants and first responders stay safe.

Grove: Designers and engineers need to be aware of the applicable codes and standards at the outset of the project, along with local amendments and guidelines. Having team members with experience in the applicable jurisdiction tends to ease the design and permitting process as well. Designers and engineers for these large projects need to be able to interpret the codes and standards properly and have the creativity to develop various means of meeting the intent of these requirements.

Regan: Design teams are constantly updated on the latest code practices and each branded hotel’s special design measures. This information is kept in a design package for a specified hotel/casino project.

CSE: How are codes, standards, or guidelines for energy efficiency impacting the design of such buildings?

Shino: From a fire protection engineering/life safety standpoint, energy efficiency has not been significantly impacted. However, because our business includes multiple disciplines, we definitely know that the last few code cycles have become more energy-focused. A project that was permitted under the 2009 IBC would have to go through a new energy evaluation to confirm compliance with the 2015 or 2018 IECC.

Regan: The impact of energy efficiency guidelines demands better and more finite engineering, which ultimately makes the project better. When energy efficiency fights resiliency, then steps are taken such that conflicting resiliency requests are in the background and not part of daily use, so their usage in a time of crisis is the only time that energy efficiency is affected.

CSE: What new code or standard do you feel will benefit hotels, casinos, and resorts? This may be a code that your AHJ has not yet adopted but will directly impact your work in the future.

CityCenter features include a 2,000-seat theater, a 150,000-sq-ft casino, an ultra-high-end retail and entertainment district, an underground parking garage, and a convention center. Courtesy: JENSEN HUGHESWhite: Thinking internationally, the IBC would benefit this industry because it provides a robust level of fire and life safety yet allows a bit of design flexibility required to meet the owner’s vision. Many international codes are not regularly updated, or they are outdated, and it is extremely difficult to design large, open public spaces under the constraints of some international codes. Macau is an example of a region that accepted the proposal to use the IBC, although they have recently retracted that right for hotel portions of the building.

Dolan: The 2015 IBC has removed the requirement for elevator hoistway venting in all occupancy types (2012 IBC, Section 3004). This will help to reduce stack effect within high-rise hotel towers by removing some openings in the exterior of the building that would otherwise require motorized smoke dampers, which are connected to the fire alarm system to seal.

Shino: “Benefit” may be a misnomer in many cases because there are typically trade-offs between requirements and cost. Certainly, technologies related to energy and building performance are the focus of most new projects, but there has to be a balance between return on investment and capital expenditure.

CSE: Give an example of a project that conflicted with what the building owner wanted and certain codes and standards. How was this situation resolved?

Regan: The owner wanted an outdoor entertainment area that was a beautiful, imported iron structure that had access only from the hotel. The fire marshal correctly required the owner to provide egress from this structure. By working with the owner, architect, and AHJ, we arrived at a solution where ironworkers modified the structure so it would appear whole from the exterior, but from the interior, code-compliant “emergency only” exit signs provided a path to newly integrated iron-gate exits controlled by the fire-control panel.

White: A common issue is how we calculate the building-occupant loading in certain types of food and beverage facilities. Dining controlled by “reservation only” or host/hostess-controlled seating have a higher reliability of occupancy control. To base the occupancy on seat count, plus a safety factor, is more indicative of a maximum load expected rather than completely overdesigning the space based on a calculated load that can be double the actual seat count. This has some benefit in terms of a reduced means-of-egress width required, which certainly adds up in fully integrated resorts that can have a calculated occupant load upwards of 60,000 to 100,000 occupants. Furthermore, it reduces the number of plumbing fixtures required while still providing a sufficient number based on actual expected maximum-occupant loads. Overly designing plumbing fixtures takes up valuable leasable real estate and carries significant costs.

Shino: This is a fairly common theme in southern Nevada, where every casino/resort wants to attract the largest crowd. For example, a common request here is installing LED-screen walls for video monitors. The IBC limits the size of plastics/screens on walls because of their inherent combustibility. The material in the video LED screens has to be shown to be compliant with relevant fire tests conducted by OSHA’s Nationally Recognized Testing Laboratories, and fire protection (sprinkler) systems are enhanced by increasing design density and/or decreasing sprinkler spacing (bringing them closer together) to mitigate the potential of a fast-spreading fire.

CSE: What challenges have you faced while trying to be code-compliant while also meeting the needs of the building owner?

Dillon: There is a multitude of new hotel “flags” entering the market, like AC Marriott and Hyatt Centric. These new flags may not have brand standards developed, or they are being developed while design is being performed. Since the flag brand is being defined, the hotel brand will often change ideas during design that will set new challenges for the design team and put pressure on the budget. A nimble team is necessary to ensure that we meet all requirements inclusive of code and the schedule.

Shino: Since each project is different, it depends on how important the noncompliant condition is versus how much the owner/designer wants the feature. In some cases, the cost is not an issue. In other cases, the owner/designer, engineering teams, and AHJ have to find a mutually agreeable midpoint. Ideally, the solution balances systems costs, safety, and the uniqueness that the owner/designer is seeking.

Grove: Many modern projects do not include operable windows or mullions for the natural ventilation of hotel guest rooms. Therefore, mechanical systems with vertical air distribution are used for these guest rooms. Mechanical engineers want to stack these outside-air ventilation systems for efficiency. The issue arises that shaft-opening protection is now required at each guest room. Per the IBC, this mandates the installation of combination fire/smoke dampers at each of these shaft openings. Fire dampers are relatively inexpensive devices, as they only require a fusible link for activation; no power or control required. Smoke dampers, however, require power to operate the motor, smoke detection to initiate closure of the damper, control of the damper (either directly from the initiating device or from the fire alarm system), and possibly monitoring of the damper position. Of course, smoke dampers are far more expensive and labor-intensive. Since an alternate only provides fire dampers at these shaft openings, we have provided redundant outside-air systems, connected to secondary power, for each of these shafts so there is always a positive pressure from the shaft to the guest rooms. We can then justify that a sprinkler-controlled fire within a guest room will not spread smoke through the shaft to other guest rooms.

White: The challenge usually lies in understanding the full intent of the code provision that is causing the hardship. Fully understanding the intent, why the provision is in the code, and perhaps the historical origin of the code allows one to begin to craft alternative means and methods to meet equivalency. For example, there was a unique ceiling design at the main entry lobby to a new project. I like to consider the main lobby the “first impression” zone, and a lot of time and effort were put forth by the owner, interior designer, and architect to deliver a magnificent first impression to arriving guests. The issue was related to NFPA 13-compliant sprinkler installations. The ceiling features consisted of curving rows of undulating metallic-bead strings. These were deemed as unacceptable obstructions that would impair the sprinkler system’s ability to operate as intended. While NFPA 13 was indeed not complied with, NFPA 13 does allow variances if the design can be demonstrated to comply with the standard’s performance criteria. We developed a full-scale mock-up of the installation and demonstrated compliance against the performance criteria. The installation was ultimately approved, and the client was able to maintain their entry lobby design.