Do Walk-In Coolers Need Title 24?

Mostly not under Part 6. A refrigerated space under 3,000 square feet is governed by the Appliance Efficiency Regulations in Title 20, and federal rules set the insulation, door and fan requirements. Part 6 asks that the unit be certified, plus glass-door light controls in a large retail food store.

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The size test

Section 120.6(a) sends refrigerated warehouses of 3,000 square feet or more, and refrigerated spaces totalling 3,000 or more served by the same refrigeration system, to the refrigerated warehouse rules. A refrigerated space under 3,000 square feet shall meet the Appliance Efficiency Regulations for walk-in coolers or freezers, Title 20, Sections 1601 through 1608. That covers the usual restaurant, laboratory or shop walk-in. The big-box version is refrigerated warehouses.

What the federal rule asks of the unit

The federal standard in 10 CFR 431.306(a) applies to walk-ins under 3,000 square feet of chilled storage, but not to products designed and marketed exclusively for medical, scientific or research use. It requires:

  • automatic door closers, except on doors wider than 3 feet 9 inches or taller than 7 feet;
  • strip doors, spring hinged doors or another way to limit infiltration;
  • wall, ceiling and door insulation of at least R-25 for coolers and R-32 for freezers, with R-28 under a freezer floor;
  • electronically commutated or three-phase evaporator fan motors under 1 horsepower, and electronically commutated, permanent-split-capacitor or three-phase condenser fan motors;
  • interior lights of 40 lumens per watt or more, unless a timer or device turns them off within 15 minutes of the space being unoccupied.

What Part 6 still touches

Section 110.1(a) lets an appliance regulated by Title 20 be installed only if it complies with Section 1608(a); check the model in the Energy Commission’s appliance database. Lighting installed by the manufacturer in a walk-in is excluded from indoor lighting power (Section 140.6(a)3E), so lights you add in the field are not. In a retail food or beverage store of 8,000 square feet or more of conditioned floor area, Section 120.6(b) requires lights on glass doors of walk-in coolers and freezers to be controlled by a time switch or motion sensor, and sets condenser rules for the store’s refrigeration systems. See commercial refrigeration, grocery stores and convenience stores.

What the code does not say

Part 6 does not define a retail food or beverage store, and it defines a restaurant separately, so the 8,000 square foot store rules are not written for a restaurant walk-in. Whether a field-run refrigerant line to a walk-in needs process pipe insulation is not addressed; the Energy Commission’s hotline can say. Kitchen context is on restaurants.

Common Title 24 Questions

  1. When does a commercial project need Title 24?
  2. Does an office tenant improvement need Title 24?
  3. Does a restaurant remodel need Title 24?
  4. Does a retail tenant improvement need Title 24?
  5. What plans are needed for a commercial Title 24 report?
  6. What is an NRCC certificate of compliance?

Frequently Asked Questions

Explore Tenant Improvements

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