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Slab on grade

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For our typical 4” slab on grade (non-structural slab) we call out #4 at 24”o.c. each way.

 

We just got by a building official plan review for not meeting the 3” min. clearance for concrete cast next to earth.  For a non-structural slab I have never worried about the bottom clearance, maybe I should be?

 

Any thoughts?  Is there a exception for non-structural concrete not needing the 3” clearance?

 

Jason