16-0215 v3.X Daylight Requirements for Retail and Food


Question 1: Please confirm if the general floor area (excluding the sales register) within a retail shop and a supermarket is considered to be a Regularly Occupied Space for the purpose of daylighting. In these spaces it is likely that staff will be moving through to tend to the stock and assisting guests as required, however the staff are likely to spend the majority of their time at their workstations or registers at specific locations throughout the store. 

Question 2: Please confirm if an exception can be granted for the daylight requirements for a supermarket, food store, shop or showroom that has food on display, where direct sunlight could be detrimental to the quality and shelf life of the produce.


Retail sales floors are not considered regularly occupied spaces. Retail shelving areas, racks, and product display areas are exempt from regularly occupied space requirements. Service counters, including but not limited to  pharmacies, cosmetics counters, checkout counters, and customer service kiosks where employees are stationed for more than 4 hours per day are considered regularly occupied spaces. The Institute is creating the following new exception for services counters where the displayed product would be damaged by direct sunlight. 

I07-E4 Retail Display Areas
Retail service counters used for the display and serving of food products or other products that are sensitive to direct sunlight may be exempt from the direct access to daylight requirement. These spaces are still required to meet the user control and outdoor air requirements stated in the Imperative, and staff in those areas should have visual access to daylight, either at a greater distance or through a nearby skylight located so that it will not impact the sensitive products.

I-07-a Supplemental Diagrams - Diagrams indicating how staff of affected areas still have access to fresh air and daylight.
I-07-b Special Use Narrative - Brief description of why affected areas could not have direct access to daylight due to their use.

Post ID 4282

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