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<![CDATA[The Building Code Blog - Blog]]>Sat, 11 Apr 2026 07:14:25 -0400Weebly<![CDATA[Portable Fire Extinguishers: Installation, Requirements, and Compliance]]>Fri, 25 Apr 2025 04:00:00 GMThttps://www.buildingcode.blog/blog/portable-fire-extinguishers-installation-requirements-and-complianceWhen it comes to fire safety within a building, fire extinguishers are not typically the first protection method that comes to mind. Fire sprinklers, fire alarm systems, smoke detectors – all are much more commonly considered when evaluating the fire safety of a building or space. However, portable fire extinguishers do play a role in the overall protection strategy of a building and are still required by the International Building Code (IBC) and International Fire Code (IFC) in most buildings. This post will explore the specific requirements, installation guidelines, and considerations for architects, designers, and building safety professionals.

All code references in this post are to the 2021 IBC and IFC or the 2022 Edition of NFPA 10, the Standard for Portable Fire Extinguishers.

What is a Portable Fire Extinguisher

According to NFPA 10, a portable fire extinguisher is “A portable device, carried or on wheels and operated by hand, containing an extinguishing agent that can be expelled under pressure for the purpose of suppressing or extinguishing fire.”

Portable fire extinguishers come in a variety of sizes, including wheeled units!

Classifying Fire Hazards and Selecting the Right Extinguisher

Fire extinguishers are categorized based on the type of fire hazard they are designed to address.

Selection of portable fire extinguishers is based on the type of fire hazard.

Let's break down the classifications of fire hazard types:

Class A Fires (Ordinary Combustibles) - Materials: Wood, paper, cloth, trash.
Class B Fires (Flammable Liquids) - Materials: Gasoline, oils, paint.
Class C Fires (Electrical) - Materials: Energized electrical equipment (e.g., wiring, circuit boards).
Class D Fires (Combustible Metals) - Materials: Magnesium, sodium, potassium.
Class K Fires (Cooking Oils and Fats) - Materials: Grease, oil, fat used in cooking.

In addition to the fire hazard classification, the IBC and IFC also consider the severity of the fire hazard, including light/low hazard, ordinary/moderate hazard and extra/high hazard. The required type of fire extinguisher is based on the classification of the fire hazard while the required size of fire extinguishers is primarily based on the severity of the hazard. We’ll cover this in more detail later in this post.

Where Are Fire Extinguishers Required

Portable fire extinguishers must be installed in multiple locations depending on the type of occupancy and the specific hazards present in a building. These requirements are found in IBC 906.1:

1. General Occupancies Fire extinguishers are required in Group A, B, E, F, H, I, M, R-1, R-2, R-4, and S occupancies, which encompass a wide variety of buildings:

Group A (Assembly): Assembly occupancies such as theaters, stadiums, and auditoriums.
Group B (Business): Offices and places of work.
Group E (Educational): K-12 schools
Group F (Factory): Manufacturing facilities.
Group H (Hazardous): Facilities dealing with dangerous chemicals or materials.
Group I (Institutional): Hospitals, nursing homes, and correctional facilities.
Group M (Mercantile): Retail spaces.
Group R (Residential): Includes hotels, dormitories, and multi-family residences.

Exceptions to the Occupancy Requirements:

Group R-2 (Residential): Extinguishers are only required in locations specified in items 2 through 6 of this list if each dwelling unit is provided with an extinguisher with a minimum rating of 1-A:10-B:C.
Group E (Schools): Extinguishers are only required in locations specified in items 2 through 6 of this list if each classroom is provided with an extinguisher with a minimum rating of 2-A:20-B:C.
Group S (Storage): For areas where forklift operators or powered industrial truck operators are the primary occupants, extinguishers can be mounted on the vehicle instead of fixed locations if approved by the fire code official.

2. Cooking Equipment: Fire extinguishers are required within 30 feet of commercial cooking equipment. Additionally, in Group I-1, I-2 Condition 1 and R-2 college dormitories, fire extinguishers are required within 30 feet of domestic cooking equipment.

3. Flammable or Combustible Liquids: Fire extinguishers are required where flammable or combustible liquids are stored, used or dispensed.

4. During Construction: Fire extinguishers are required on every floor of structures under construction with the exception of Group R-3 occupancies. See IFC 3315.1 for additional information.

5. Other Locations: Fire extinguishers are required in certain special situations by the IFC. Refer to IBC Table 906.1 which provides a list of these situations.

6. Special Hazard Areas: Fire extinguishers are required in special hazard areas including laboratories, computer rooms and generator rooms where required by the fire code official.

Extinguisher Size, Distribution, and Rating

The IBC requires fire extinguishers to be sized and distributed based on a variety of factors including fire classification, hazard type, and floor area.

Class A Fire Hazards

Fire extinguishers for Class A fire hazards must comply with the following per IBC 906.3.1:

Hazard Type	Minimum Extinguisher Rating	Max Area Covered Per Unit of A (sq. ft.)
Light (Low)	2-A (or two 1-A extinguishers)	3,000
Ordinary (Moderate)	2-A	1,500
Extra (High)	4-A (or two 2.5 gallon water-type extinguishers)	1,000

Class B Fire Hazards

Fire extinguishers in locations with flammable or combustible liquids with depths less than or equal to ¼-inch must comply with the following per IBC 906.3.2:

Hazard Type	Minimum Extinguisher Rating	Max Travel Distance to an Extinguisher (feet)
Light (Low)	5-B 10-B	30 50
Ordinary (Moderate)	5-B 10-B	30 50
Extra (High)	5-B 10-B	30 50

Fire extinguishers in locations with flammable or combustible liquids with depths greater than ¼-inch must comply with the requirements found in NFPA 10.

Class C Fire Hazards

Fire extinguishers for Class C fire hazards must be selected and placed based on the anticipated Class A or B hazard.

Class D Fire Hazards

Fire extinguishers in locations with combustible metals must comply with requirements found in NFPA 10.

Cooking Equipment Fires

Fire extinguishers in locations with cooking equipment must be approved and compatible with the automatic fire extinguishing system used for the cooking equipment. If the cooking equipment involves solid fuels, vegetable/animal oils or fats, a Class K fire extinguishers is required. Refer to Section 906 of the IFC for additional information.

Installation Requirements and Guidelines

Correct installation is as crucial as the right selection of fire extinguishers. Section [F] 906.9 outlines specific requirements for installation:

1. Installation Height

Extinguishers weighing 40 pounds or less: The top of the extinguisher should not be more than 5 feet above the floor. This ensures ease of access in case of an emergency.
Extinguishers weighing more than 40 pounds: These must be installed so that the top is no more than 3.5 feet from the floor to ensure accessibility.

2. Floor Clearance

All fire extinguishers must have at least 4 inches of clearance from the floor to prevent them from being obstructed by debris or other objects.

3. Conspicuous and Unobstructed Location

Fire extinguishers must be placed in conspicuous locations where they are easily visible and accessible. They should not be blocked or obscured by furniture, storage, or any other objects.

4. Cabinet Requirements

Cabinets used to house extinguishers should not be locked unless specific exceptions apply, such as for Group I-3 (detention facilities) or in cases where malicious damage could occur. In these instances, staff should have access to keys.

Conclusion

Portable fire extinguishers are required in most buildings and occupancies. Selection and placement of portable fire extinguishers varies based on the type of hazards present and and the type of extinguisher being provided.

]]><![CDATA[High-Rise Building Requirements: An Overview for Architects and Engineers]]>Wed, 19 Mar 2025 04:00:00 GMThttps://www.buildingcode.blog/blog/high-rise-building-requirements-an-overview-for-architects-and-engineersThe design and construction of high-rise buildings come with unique challenges, particularly when it comes to fire and life safety. The 2021 International Building Code (IBC) outlines specific requirements for high-rise buildings that affect construction type, fire protection, egress, and emergency systems. These requirements play a major role in the design of a high-rise building, so it’s important for architects and engineers to know and understand the requirements from the beginning of the design process.

In this article, we’ll provide an overview of the key requirements from the 2021 IBC that apply to high-rise buildings.

If you're interested in a cheat sheet that summarizes these requirements, scroll down to the bottom of the article to download your free one-page cheat sheet.

What is a High-Rise Building?

Per the 2021 IBC, a high-rise building is defined as:

A building with an occupied floor located more than 75 feet above the lowest level of fire department vehicle access."

Any building with an occupied floor higher than this 75 foot threshold is considered a high-rise building and must comply with all of the requirements listed in this article.

Starting in the 2024 IBC, the definition of high-rise building has been changed to be:

A building with an occupied floor or occupied roof located more than 75 feet above the lowest level of fire department vehicle access."

This new definition means that an occupied roof above the 75 foot threshold now also will trigger designation as a high-rise building.

Construction Type and Fire Resistance Ratings

The IBC establishes fire resistance rating requirements based on building height and occupancy type. High-rise buildings generally fall under Type I construction, which mandates noncombustible materials with high fire resistance ratings. However, some reductions are permitted (IBC 403.2.1):

For buildings ≤ 420 feet, fire resistance ratings can be reduced to Type IB, except for columns supporting floors.
For most occupancies, the ratings for Type IB can be further reduced to Type IIA, except for Groups F-1, H, M, and S-1.
Despite reductions, height and area limitations remain based on the original construction type before reductions.
In buildings ≤ 420 feet, shaft fire barriers (except for interior exit stairs and elevators) may be reduced to 1-hour rated if sprinklers are installed at the top and at alternate floors.

Structural Integrity

Shaft enclosures play an important role in maintaining fire and smoke compartmentation. Key requirements include (IBC 403.2.2):

For buildings > 420 feet or those classified as Risk Category III or IV, interior exit stair and elevator hoistway enclosures must meet one of the following impact resistance requirements:
- Two layers of Hard Body Impact Level 2 panels
- One layer of Hard Body Impact Level 3 panels
- Multiple layers of any material meeting Hard Body Impact Level 3
Concrete or masonry walls automatically meet these requirements.
Sprayed Fire-Resistant Materials (SFRM) must meet specific bond strength requirements:
- ≥ 430 psf for buildings ≤ 420 feet
- ≥ 1,000 psf for buildings > 420 feet

Fire Sprinkler Systems

High-rise buildings must be fully sprinkler-protected per NFPA 13. Additional fire suppression measures include (IBC 403.3):

For buildings > 420 feet:
- A minimum of two sprinkler risers, supplying alternate floors, located in separate exit stairs.
- Fire pumps must be supplied by at least two water mains from different streets (or two connections to one main with isolation valves).
Seismic Design Categories C, D, E, or F: A secondary on-site water supply is required.

Fire Alarm and Smoke Detection Systems

Fire detection and alarm systems play a big role in the safety of high-rise buildings. Key requirements include (IBC 403.4):

Smoke detection in mechanical, electrical, and transformer rooms not protected by sprinklers.
Smoke detection in elevator machine/control rooms and lobbies.
Duct smoke detection required in:
- Return/exhaust plenums of HVAC systems > 2,000 CFM.
- Each return connection to duct risers serving two or more stories.
Emergency voice/alarm communication system required.

Fire Department Response

High rise buildings pose a unique challenge to responding fire departments. To assist local fire departments, the following features a required:

A Fire Command Center (FCC) is required to centralize emergency response operations.
Post-fire smoke removal must be provided through either operable windows/panels or a mechanical system.
Fire department communication system required (emergency responder radio enhancement or wired system where approved).
A standpipe system is required

Egress and Stairway Design

Ensuring proper means of egress is critical in high-rise buildings. The IBC includes the following key stairway requirements:

At least two interior exit stairs must be 30 feet apart or ¼ of the diagonal distance of the area served.
For buildings > 420 feet (except Group R-2): An additional exit stair is required beyond the base requirements of IBC Chapter 10. An occupant evacuation elevator can be provided instead of this extra stair.
Stairway doors may be locked from the stair side if they can be unlocked simultaneously from the Fire Command Center. Two-way communication devices required at every fifth floor if stairway doors are locked.
Smokeproof enclosures required for interior exit stairs serving floors > 75 feet above fire department access. This is most commonly achieved by stairway pressurization, but can also be done using other methods.
Luminous egress path markings required in Group A, B, E, I-1, M, and R occupancies.

Elevator Requirements

Elevators play a key role in both evacuation and firefighter access in high-rise buildings. The 2021 IBC requires:

For buildings > 120 feet: At least two fire service access elevators (or all elevators must meet fire service access requirements).
- Each elevator must have a minimum capacity of 3,500 pounds.
- Elevators must have lobby and direct stair access per IBC 3002.4.
Occupant evacuation elevators are permitted as an alternative to an additional exit stair in buildings > 420 feet.

Emergency Power and Fire Command Center

To support critical life safety systems, high-rise buildings must have emergency power systems:

Generators must be housed in a 2-hour rated room, with fuel lines protected in 2-hour enclosures or by other approved methods.
Emergency power must be provided for additional required systems, including fire alarms, elevators, and life safety systems.

Conclusion

High-rise buildings are among the most complex structures from a code compliance perspective. The 2021 IBC outlines extensive requirements covering construction type, fire protection, egress, elevators, and emergency systems. While some provisions allow for flexibility, such as fire resistance reductions and alternative egress solutions, most of these requirements are above and beyond what is required in smaller building. Understanding and integrating these high-rise requirements early in the design process helps streamline approvals and avoid costly redesigns.

Free High Rise Code Requirements Cheat Sheet

]]><![CDATA[Is an Opening in a Fire Wall Automatically a Horizontal Exit?]]>Tue, 10 Dec 2024 05:00:00 GMThttps://www.buildingcode.blog/blog/is-an-opening-in-a-fire-wall-automatically-a-horizontal-exitIn projects of Type II, III, IV or V construction, architects are often forced to balance the allowable area limits of lesser construction types with the added cost of higher construction types. A fire wall is an ideal solution, as it allows for the cost savings of a lower construction type while allowing the structures on either side of the fire wall to be considered independently from an allowable area standpoint.

On several recent projects, I have seen plan reviewers treat any door opening in the fire wall as a horizontal exit, even if that was not the design team’s intention. The reviewers then issued permit comments regarding compliance with the horizontal exit code requirements. This has led me to the question: is an opening in a fire wall automatically a horizontal exit?

A pair of opposing doors in a fire wall.

Before I get to my answer, you might be asking: why does this matter?

Horizontal Exit Code Requirements

Horizontal exits come with several code requirements, but in the recent projects I mentioned, the plan reviewers were citing the following:

Horizontal Exit Egress Capacity

Per IBC 1026.1, a horizontal exit can provide up to one half of the total number of exits, total exit width and total egress capacity. So if the door in the fire wall is a horizontal exit, then it cannot provide more than half of the required number of exits or required exit width. If you have a single door in the fire wall and then an exit stair on either side, this is no problem. But once you have multiple doors in the fire wall, the horizontal exit can easily exceed one half of the total required exits/width.

Horizontal Exit Refuge Area

Per IBC 1026.4, when a horizontal exit approach is used, a refuge area is required in the space on the other side of the horizontal exit. This refuge area must be large enough to provide three square feet per occupant for the original occupant load of the space each occupant entering into the refuge area from the horizontal exit.

Depending on the building arrangement and capacity, providing this refuge area may be a design challenge.

Horizontal Exit Standpipe Hose Connections

Per IBC 905.4.2, a standpipe hose connection is required on each side of a horizontal exit. An exception does exist if the floor areas adjacent to the horizontal exit are within 130’ of standpipe hose connection with an exit stair.

So if any door in a fire wall is a horizontal exit, each of these code requirements must be met, adding additional cost and design coordination.

Coming back to the original question:

Is an opening in a fire wall automatically a horizontal exit?

I believe the answer is no. A door opening in a fire wall can be a horizontal exit, but it is not required to be a horizonal exit.

My opinion is based on a few factors.

First, let’s look at the definition of fire wall (IBC Chapter 2):

A fire-resistance-rated wall having protected openings, which restricts the spread of fire and extends continuously from the foundation to or through the roof, with sufficient structural stability under fire conditions to allow collapse of construction on either side without collapse of the wall.”

This definition does not mention or describe a horizontal exit at all.

Similarly, we can go to IBC Chapter 5, where the general requirements for building height and area are given. Per IBC 503.1:

For the purposes of determining area limitations, height limitations and type of construction, each portion of a building separated by one or more fire walls complying with Section 706 shall be considered to be a separate building.”

This statement indicates that a fire wall creates separate buildings for the purposes of allowable height/area and construction type, but again, it does not mention or describe a horizontal exit.

Finally, if we return to the horizontal exit section of IBC Chapter 10, we see in Section 1026.2 that a horizontal exit is permitted to be provided as either a fire wall or a fire barrier. No where in this section is a fire wall required; it is just given as one of two options. I have never heard of any AHJ requiring all fire barriers to be a horizontal exit, so why would we apply that logic to fire walls?

Icing on the Cake: An ICC Committee Interpretation

I am not the first person to ask this question, and fortunately, the ICC released a committee interpretation on this same issue a few years ago.

To summarize the committee’s interpretation, fire door openings in a fire wall are not required to be considered as a horizontal exit unless the design of the egress system intends to utilize the provisions of a horizontal exit.

Conclusion

While you would think that the code support described above, plus an ICC committee interpretation would be sufficient to persuade any AHJ, I have still experience pushback on this issue from plan reviewers.

Despite this, I believe the intent of the code is to allow a door in a fire wall to be used as a horizontal exit, but not require it. And if the design intention is not to utilize the horizontal exit provisions, then you do not need to be concerned about the exit capacity restrictions, refuge area requirements and additional standpipe hose connections that I described previously.

Have you encountered a similar issue before? If so, please comment below and let me know.

]]><![CDATA[Guide to Locking Egress Doors]]>Thu, 14 Nov 2024 05:00:00 GMThttps://www.buildingcode.blog/blog/guide-to-locking-egress-doorsIn almost every building, owners or tenants have a need for some level of security or access control. The IBC covers a wide range of door locking and control techniques, but the shear number of sections and underlying requirements can be tough to digest. Many folks have trouble knowing which code sections apply, and even if the correct section is identified, it can be a challenge to understand the requirements.

In this post, I take a number of these door locking requirements and translate them into (hopefully) more clear and concise language. I also provide some general commentary on my experience in using each type of door/locking arrangement. References are provided to the last 4 editions of the IBC. All references within the article itself are to the most recent code edition.

Click one of the door/lock types in table below to jump to that section.

Component	2015 IBC	2018 IBC	2021 IBC	2024 IBC
Revolving Doors	1010.1.4.1	1010.1.4.1	1010.3.1	1010.3.1
Power-Operated Doors	1010.1.4.2	1010.1.4.2	1010.3.2	1010.3.2
Special Purpose Horizontal Sliding, Accordion or Folding Doors	1010.1.4.3	1010.1.4.3	1010.3.3	1010.3.3
Educational Occupancies	-	1010.1.4.4	1010.2.8	1010.2.7
Security Grilles	1010.1.4.4	1010.1.4.5	1010.3.4	1010.3.4
Group I-1 and I-2 Controlled Egress	1010.1.9.6	1010.1.9.7	1010.2.14	1010.2.13
Delayed Egress	1010.1.9.7	1010.1.9.8	1010.2.13	1010.2.12
Sensor Release of Electrically Locked Doors	1010.1.9.8	1010.1.9.9	1010.2.12	1010.2.11
Electromagnetically Locked Doors	1010.1.9.9	-	-	-
Door Hardware Release of Electrically Locked Doors	-	1010.1.9.10	1010.2.11	1010.2.10
Correctional Facilities	1010.1.9.10	1010.1.9.11	1010.2.15	1010.2.15
Stairway Doors	1010.1.9.11	1010.1.9.12	1010.2.7	1010.2.6
Panic and Fire Exit Hardware	1010.1.10	1010.1.10	1010.2.9	1010.2.8
Elevator Lobby Exit Access Doors	-	-	-	1010.2.14

Revolving Doors

Many designers don't realize that a revolving door can be used in an egress path, as long as certain requirements are met.

All revolving doors must meet the following requirements, but be sure to check out the paragraph below this one for additional requirements for egress/non-egress doors.

Comply with BHMA A156.27 and the manufacturer's instructions.
Each revolving door must have "breakout" capability per BHMA A156.27 and have an aggregate width of at least 36 inches.
A revolving door must be at least 10 feet from the top or bottom of stairs and escalators. A dispersal area must be provided between the stair/escalator and the revolving doors.
The revolving door speed (in RPMs) cannot exceed the maximum rpm as specified in BHMA A156.27. Manual revolving doors must comply with Table 1010.1.4.1(1). Automatic or power-operated revolving doors shall comply with Table 1010.1.4.1(2).
An emergency stop switch is required near each entry point of power or automatic operated revolving doors within 48 inches of the door and between 24 inches and 48 inches above the floor. The activation area of the emergency stop switch button must be at least 1 inch in diameter and red in color.
Each revolving door must have a side-hinged swinging door that complies with IBC 1010.1 in the same wall and within 10 feet of the revolving door.
Revolving doors cannot be part of a required accessible route.

Manual Revolving Doors
Max Door Speed

Door Diameter (Feet)	Max Speed (RPM)
6	12
7	11
8	10
9	9
10	8

Auto/Power Revolving Doors
Max Door Speed

Door Diameter (Feet)	Max Speed (RPM)
8	7.2
9	6.4
10	5.7
11	5.2
12	4.8
12.5	4.6
14	4.1
16	3.6
17	3.4
18	3.2
20	2.9
24	2.4

Revolving Doors in Egress Components must meet the following requirements:

Count towards no more than 50% or required egress width or capacity.
Each door counts towards a maximum of 50 occupants when performing egress calculations.
Maximum breakout force of 130 pounds.

Revolving doors that are not egress components must have a breakout force of 180 pounds or less. A breakout force of more than 180 pounds is permitted if the breakout force reduces to 130 pounds or less under one of the following conditions:

Door power failure
Sprinkler system activation
Smoke detector activation with 75 feet of the revolving doors
Activation of a manual control switch in a clearly identified location

Power-Operated Doors

Power operated doors are common in building entrances, as well as in occupancies where people may struggle to open a door by themselves, such as a Group I-2 nursing home.

Horizontal sliding doors, like you might see an an airport, are an example of power operated doors.

Any egress door that is operated or assisted by power must have the capability to be manually opened or closed. The forces required to open the doors must comply with IBC 1010.1.3 door opening force requirements, except the force to set the door in motion must not exceed 50 pounds. The door must have the capability to open from any position to the full width of the opening when a force is applied on the egress side.

Power-operated swinging doors, power-operated sliding doors and power-operated folding doors must comply with BHMA A156.10. Power-assisted swinging doors and low-energy power-operated swinging doors must comply with BHMA A156.19. (2018 and Beyond): Low-energy power-operated sliding doors and low-energy power-operated folding doors must comply with BHMA A156.38.

Exceptions to the above requirements:

Group I-2 occupancies
Special purpose horizontal sliding, accordion or folding doors (see related section in this article)
For a biparting door in the emergency breakout mode, a door leaf located within a multiple-leaf opening is exempt from the minimum 32-inch single-leaf requirement, provided that a minimum 32-inch clear opening is provided when the two biparting leaves meeting in the center are broken out.

Special Purpose Horizontal Sliding, Accordion or Folding Doors

Special purpose doors, such as horizontal sliding doors, are most commonly used in situations where a fire door is needed in an egress path but there is a desire to have the door normally open, or perhaps concealed. A sliding or folding fire shutter would fall into this category. These are the only type of doors in this article that specifically require an integrated standby power supply, typically provided as a battery pack above the door.

A horizontal sliding fire door with egress functionality (image courtesy of Won-Door).

Horizontal sliding, accordion or folding doors can be used in all occupancies except Group H when allowed by Exception 6 of IBC 1010.1.2. Use of these doors requires the following (IBC 1010.3.3):

The doors are power operated and are capable of being operated manually in the event of power failure.
The doors are openable by a simple method from both sides without special knowledge or effort.
The force required to operate the door cannot exceed 30 pounds to set the door in motion and 15 pounds to close the door or open it to the minimum required width.
The door must be openable with a maximum force of 15 pounds when a force of 250 pounds is applied perpendicular to the door adjacent to the operating device.
The door assembly must comply with the applicable fire protection rating and, where rated, must be:
1. Self-closing or automatic closing by smoke detection in accordance with IBC 716.2.6.6.
2. Installed in accordance with NFPA 80.
3. Comply with IBC 716.
The door assembly must have an integrated standby power supply.
The door assembly power supply must be electrically supervised.
The door must open to the minimum required width within 10 seconds of the operating device.

Locking Arrangements in Educational Occupancies

Locking of egress doors in educational occupancies has been a hotly-debated topic in recent code cycles. Some argue that being able to lock a classroom door from the inside is necessary to protect occupants during certain emergency situations. Others argue that this actually poses a greater risk to occupants inside the classroom. The requirements for such locking arrangements are provided below.

In Group E occupancies, Group B educational occupancies and (2021/2024 only) Group I-4 occupancies, egress doors from classrooms, offices and other occupied rooms with locking arrangements designed to keep intruders from entering the room are permitted with the following requirements:

The door is capable of being unlocked from outside the room with a key or other approved method. Remote door unlocking is permitted in addition to the key.
The door is openable from within the room per IBC 1010.2
Modification are not permitted to listed panic hardware, fire door hardware or closers.
(2021/2024 only) Modifications to fire doors assemblies must be in accordance with NFPA 80.

Security Grilles

Security grilles are an important part of building security systems, particularly in retail spaces such as a shopping mall. The IBC allows security grilles in Group M occupancies, as well as Groups B, F and S.

In Groups B, F, M and S, horizontal sliding or vertical security grilles are permitted at the main exit and must be openable from the inside without the use of a key, special knowledge or effort when the space is occupied. The grilles must remain secured in the full-open position anytime the space is occupied by the general public. Where two or more means of egress are required, no more than half of the exits or exit access doorways can be equipped with security grilles.

Group I-1 and I-2 Controlled Egress Doors

Group I-1 and I-2 occupancies include assisted living facilities, nursing homes, hospitals, psychiatric treatment centers, all facilities where people receiving care may require some level of containment. There are many situations where allowing a care recipient to freely exit may actually endanger that person or others. The IBC recognizes this risk and provides an avenue to provide locking control on egress doors in such occupancies.

Electric locking systems are permitted in Group I-1 and I-2 occupancies where the clinical needs of the care recipient require their containment. In order to use this code provision, the building must be either fully sprinkler-protected or equipped throughout with smoke detectors and meet all of the following requirements:

The door must unlock upon actuation of the sprinkler or smoke detection system, allowing immediate free egress.
The door must unlock upon power loss, allowing immediate free egress.
The door must have an unlocking switch, located at the fire command center, nursing station or other approved location, that directly breaks power to the lock.
No more than one controlled egress door before reaching an exit
Door unlocking procures must be included and approved in the required Fire Code emergency planning (see IFC Chapter 4).
All clinical staff must have a key or other means to operate the locked door
Emergency lighting is required at the door.
The door locking system must be UL 294 listed.

Exceptions: Items 1-4 above do not apply to the following situations:

Areas where persons require restraint or containment as part of the function of a psychiatric treatment area or (2021 only) cognitive treatment area.
Where a listed egress control system is used to reduce child abduction risk from nursery and obstetric area of a Group I-2 hospital.

Delayed Egress

Using a delayed egress system is one of the most common approaches to achieve some level of access control on an egress door. They provide a deterrent to occupants using the door unless there is a true need (e.g. a fire emergency), but still allow for full egress use after the delay period. A key limitation of delayed egress systems is they are limited by occupancy , for example, Group A spaces cannot use delayed egress systems, regardless of the occupant load.

Where permitted:

2015:
Delayed egress locking systems are permitted in any occupancy except Groups A, E or H when the building is fully sprinkler protected per NFPA 13 or provided with smoke/heat detection throughout.

2018 and Beyond:
Delayed egress locking systems are permitted in the following situations when the building is fully sprinkler protected per NFPA 13 or provided with smoke/heat detection throughout.

Group B, F, I, M, R, S and U
Group E classrooms with an occupant load less than 50
In courtrooms, on other than the main exit doors, when the building is fully sprinkler protected per NFPA 13.

The delayed egress locking system must meet all of the following requirements:

The delay electronics must allow immediate and free egress upon actuation of the sprinkler system or fire detection system.
The delay electronics must allow immediate and free egress upon power loss.
The delay electronics must have the capability to be deactivated from the fire command center or other approved location.
When an effort is applied to the egress door hardware for not more than 3 seconds, an irreversible process must star that allows for the egress door to open in 15 seconds or less. The irreversible process must activate an audible signal near the door. Once the delayed egress door has been deactivated, the door can only be rearmed by manual means.
1. Exception: Where approved by the AHJ, a delay of not more than 30 seconds is permitted.
The egress path cannot pass through more than one delayed egress locking system.
1. 2015 Exception: In Groups I-2 or I-3, the egress path can pass through up to two delayed egress locking systems if the combined delay is 30 seconds or less.
2. 2018 Exception: In Groups I-2 or I-3, the egress path can pass through up to two delayed egress locking systems if the combined delay is 30 seconds or less. In Groups I-1 or I-4, the egress path can pass through up to two delayed egress locking systems if the combined delay is 30 seconds or less and the building is fully sprinkler protected per NFPA 13.
3. 2021/2024 Exception: In Groups I-1 Condition 2, I-2 or I-3, the egress path can pass through up to two delayed egress locking systems if the combined delay is 30 seconds or less. In Groups I-1 Condition 1 or I-4, the egress path can pass through up to two delayed egress locking systems if the combined delay is 30 seconds or less and the building is fully sprinkler protected per NFPA 13.
A sign must be provided on the door and located above and within 12 inches of the door exit hardware:
1. For doors swinging in direction of egress, the sign must read “PUSH UNTIL ALARM SOUNDS. DOOR CAN BE OPENED IN 15 [30] SECONDS.”
2. For doors swinging in against the direction of egress, the sign must read “PULL UNTIL ALARM SOUNDS. DOOR CAN BE OPENED IN 15 [30] SECONDS.”
3. The sign must comply with the visual character requirements in ICC A117.1.
4. Exception: Where approved in Group I occupancies, the sign is not required where care recipients have a clinical needs requiring restraint or containment as part of the function of the treatment area.
Emergency lighting must be provided on the egress side of the door.
The delayed egress systems must be UL 294 listed.

Sensor Release of Electrically Locked Doors

Electrically locked doors using a sensor release are frequently used in situations where it is helpful to have an egress door unlock prior to an occupant physically reaching the door. Note that this type of door release functionality can be used in conjunction with an electromagnetic locking mechanism (Mag Lock).

Sensors must be mounted such that the door unlocks as an occupant is approaching.

Where Permitted:

2015:
Sensor release locks are permitted on any egress door in Groups A, B, E, I-1, I-2, I-4, M, R-1 or R-2 occupancy.

2018 and Beyond:
Sensor release locks are permitted on any egress door except in Group H occupancies.

Sensor release locks must be installed and operated per the following requirements:

Sensor installed on egress side of door to detect an occupant approaching the door and cause the electric lock system to unlock.
Door unlocks upon loss of power or signal to the sensor.
Door unlocks upon loss of power to the lock or locking system.
Doors can be unlocked from a manual device located 40” to 48” above the floor and with 5 feet of the doors. The unlocking device must be readily accessible and be clearly identified with a “PUSH TO EXIT” sign. The unlocking device must directly interrupt power to the lock independent of other electronics and keep the door unlocked for at least 30 seconds.
Door unlocks upon activation of the building fire alarm system and remain unlocked until fire alarm system is reset.
Door unlocks upon activation of the sprinkler system or fire detection system and remain unlocked until the fire alarm is reset.
Door lock system must be UL 294 listed or (2024 only) UL 1034 listed.
(2021/2024 Only) Emergency lighting must be provided on the egress side of the door.

Electromagnetically Locked Doors

Electromagnetically locked egress doors, commonly referred to as “Mag Locks” are permitted in Group A, B, E, I-1, I-2, M, R-1 and R-2 occupancies. Use of such locks requires a built-in switch on the door and compliance with the following:

Hardware is affixed directly to the door leaf and has an obvious method of operation under all lighting conditions.
Hardware can be operated with one hand.
Operating the door hardware immediately interrupts power to the Mag Lock and unlocks the door immediately.
Door unlocks upon lows of power to the locking system.
Where panic or fire exit hardware is required, operation of that hardware also releases the Mag Lock.
Lock system must be UL 294 listed.

Door Hardware Release of Electrically Locked Doors

Starting in 2018, the Mag Lock section above was expanded to any electric locking system with a door hardware release. The requirements here are essentially the same as the Mag lock requirements from 2015.

Door hardware release of electric locking systems on egress doors is permitted in all occupancies except Group H and requires compliances with the following:

Hardware is affixed directly to the door leaf and has an obvious method of operation under all lighting conditions.
Hardware can be operated with one hand and meets IBC unlatching requirements.
Operating the door hardware immediately interrupts power to the lock and unlocks the door immediately.
Door unlocks upon lows of power to the locking system.
Where panic or fire exit hardware is required, operation of that hardware also releases the lock.
Lock system must be UL 294 listed or (2024 only) UL 1034 listed.

Correctional Facilities

Correctional and detention facilities are permitted to have locked egress doors when occupants are required to have controlled movements for security purposes. Such doors must have an egress control devices that unlocks the door manually and by at least one of the following means:

Activation of the building sprinkler system
Actvaition of a manual fire alarm pull station
A signal from a constantly attended location.

In the 2015 IBC, use of this provision is limited to Groups A-2, A-3, A-4, B, E, F, I-2, I-3, M and S occupancies within correctional and detention facilities. In 2018 and beyond, use of this section is permitted in any building within a correctional and detention facility.

Stairway Doors

In some cases, stair doors can be locked from the inside.

Generally, interior stair doors must be openable from both sides without the use of a key or special knowledge, though the following exceptions allow you to lock the stair door:

Stair discharge doors can be locked from the outside (must be unlocked in direction leaving the stair).
Stair doors in high rise buildings complying with IBC 403.5.3 (see section below).
(2015 Only): In stairs serving 4 stories or fewer, stair doors can be locked from the inside provide they have the capability of being simultaneously unlocked (without unlatching) by a signal from the fire command center or location inside the main entrance of the building.
(2018/2021): Stair doors can be locked from the inside provide they have the capability of being simultaneously unlocked (without unlatching) by a signal from the fire command center or location inside the main entrance of the building.
(2024 Only): Stair doors can be locked from the inside provided they have the capability of being unlocked without unlatching by any of the following:
1. Individual or simultaneous unlocking by a signal from the fire command center or location inside the main entrance of the building.
2. Simultaneous unlocking upon activation of a fire alarm signal.
3. Upon failure of the power supply to the electric lock or locking system.
Stair doors in Group B, F, M and S occupancies where the only interior access to a tenant space is from the exit stair can be locked from the inside of the stair (must be unlocked in direction of egress).
Stair doors in Group R-2 dwelling units where the only interior access to the unit is from the exit stair can be locked from the inside of the stair (must be unlocked in direction of egress).

In high rise buildings, stairway doors can be unlocked from the stairway side provided they have the capability of being unlocked (without unlatching) by a signal from the fire command center. when this provision is used, a telephone or other two-way communication system connected to a constantly attended location is required on every fifth floor in every stairway with locked doors.

Panic and Fire Exit Hardware

Panic and fire exit hardware itself does not involve locking a door. Rather, panic or fire exit hardware can be used in conjunction with one of the locking arrangement described in this article.

Elevator Lobby Exit Access Doors

In the 2024 IBC, a new allowance was introduced allowing for the electrical locking of exit access doors providing egress from elevator lobbies. This new allowance requires compliance with the following:

All occupants on the floor have access to at least two exits without passing through the lobby.
The building is fully sprinkler-protected per NFPA 13, equipped throughout with an NFPA 72 fire alarm system and the elevator lobby is equipped with smoke detection.
Upon activation of the fire alarm system by any means besides a manual pull station, the elevator lobby doors automatically unlock and remain unlocked until the fire alarm system is reset.
The locks unlock upon loss of power to the locks or locking system.
The locks have the capability of being unlocked by a switch at the fire command center, security station or other approved location.
A two way communication system complying with IBC 1009.8.1 and 1009.8.2 is located in the lobby adjacent to the locked door and connected to an approved constantly attended location that has the ability to unlocked the lobby doors.
Emergency lighting is provided on both sides of the locked lobby door(s).
The locking devices is listed to UL 294 or UL 1034.

Conclusion

There are numerous options in the IBC for providing some form of access control on egress doors. Keep in mind that these code references typically only apply in the direction of egress (stairway doors being a notable exception). If a door (or one side of a door) is not part of the egress path, the code generally allows locking of the door.

]]><![CDATA[Code Change Proposal FS47 - Firestopping of Floor Penetrations in Parking Structures]]>Tue, 05 Nov 2024 13:25:39 GMThttps://www.buildingcode.blog/blog/code-change-proposal-fs47-firestopping-of-floor-penetrations-in-parking-structuresThis post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH).

Please note that I am serving on the 2024-2026 IBC Egress Committee, so many of these articles in this series will be egress related. Each post is my attempt to summarize the code change proposal and the presentation/discussion from CAH1, but please refer to the links below that include the actual code change proposal language and the CAH1 recording. These posts are not intended to provide my personal opinion or commentary on the code changes.

Code Change Proposal FS47 - Firestopping of Floor Penetrations in Parking Structures
Link: Code Change Proposal
Link: Hearing Recording

Summary of Code Change
This proposal would require firestopping of penetrations through the floor slabs of parking garages.

Summary of Testimony and Discussion
Several participants testified in support of this proposal, stating that the firestopping of these penetrations would help to limit floor to floor fire spread.

Several participants testified in opposition of this proposal, noting that the code allows numerous other vertical openings within parking garages, such as ramps, ducts and elevators, to be unprotected. They stated that it does not make sense to protect pipe penetrations while still allowing all of these other vertical openings.

CAH1 Result
This code change proposal was approved by the committee, with a vote of 7-4

]]><![CDATA[Code Change Proposal E125 - Accessible Route to Performance Areas]]>Tue, 29 Oct 2024 04:00:00 GMThttps://www.buildingcode.blog/blog/code-change-proposal-e125-accessible-route-to-performance-areasThis post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH).

Code Change Proposal E125 - Accessible Route to Performance Areas

Link: Code Change Proposal
Link: Hearing Recording

Summary of Code Change
This proposal seeks to clarify that the location of accessible routes to a performance needs to be in the same area as the circulation path. Additionally, the proposal requires that the audience's sightline to this accessible route must be comparable to the audience's sightline to the circulation path.

Summary of Testimony and Discussion
Two participants testified in support of this proposal, essentially stating that equal access to the performance area necessitates the accessible route being in the same area and vicinity as the regular circulation path. Requiring an occupant using a mobility devices to take a substantially different route to the performance area should not be considered equivalent access.

There was no testimony in opposition of this proposal.

CAH1 Result
This code change proposal was approved by the committee, with a vote of 14-0.

]]><![CDATA[A2L Refrigerants: A Code Requirement Overview]]>Fri, 11 Oct 2024 13:29:35 GMThttps://www.buildingcode.blog/blog/a2l-refrigerants-a-code-requirement-overviewAs the global push towards environmentally friendly solutions continues, the HVAC industry has been experiencing a shift in refrigerant technology. A2L refrigerants, categorized as "mildly flammable,” have been a hot conversation topic in the construction community. The push towards eliminating A1 refrigerants, which have a higher Global Warming Potential (GWP), has coincided with additional design requirements for A2L refrigerants that have been challenging for many architects and engineers.

In this article, we'll provide a detailed overview of A2L refrigerants, touching on everything from their fundamental characteristics to the critical code requirements surrounding their installation and use.

What are A2L Refrigerants?

A2L refrigerants are a class of mildly flammable refrigerants, developed as part of the HVAC industry’s transition to more environmentally friendly alternatives. These refrigerants fall under the A2L classification according to ASHRAE Standard 34, where “A” indicates low toxicity, and “2L” signifies low flammability with limited flame propagation. The adoption of A2L refrigerants, such as R-32 and R-454b, is driven by their significantly lower Global Warming Potential (GWP) compared to traditional refrigerants like R-410a and R-134a.

New regulations related to refrigerants are forcing major changes to the HVAC industry.

What Federal Regulations are Driving A2L Refrigerants

The federal regulation driving the use of A2L refrigerants in the United States is the American Innovation and Manufacturing (AIM) Act, signed into law in December 2020. The AIM Act gives the Environmental Protection Agency (EPA) authority to phase down the production and consumption of hydrofluorocarbons (HFCs), which are high Global Warming Potential (GWP) refrigerants widely used in air conditioning, refrigeration, and other cooling systems.

The AIM Act aligns the U.S. with the Kigali Amendment to the Montreal Protocol, a global agreement aimed at reducing the environmental impact of HFCs, which are potent greenhouse gases. The Kigali Amendment sets a timeline for the phasedown of HFCs over the next few decades to help limit global warming. A2L refrigerants, which have significantly lower GWP compared to traditional HFCs like R-410A and R-134a, are part of the solution for transitioning to more sustainable alternatives.

Under the AIM Act, the EPA has implemented a schedule for reducing HFC consumption by 85% over the next 15 years. This creates a regulatory push for HVAC manufacturers, contractors, and building owners to adopt low-GWP alternatives, such as A2L refrigerants. Additionally, the EPA is working on updating safety standards, building codes, and certification requirements to ensure that the adoption of A2L refrigerants is done in a safe and compliant manner.

There have been a number of published rules and rule updates, but the most recent regulations for residential and light commercial HVAC systems have the following requirements:

Prohibit the manufacture and import of HVAC products with GWPs > 700 on or after January 1, 2025
Prohibit the sale, distribution, and export of products with GWPs > 700 on or after January 1, 2028
Prohibit the installation of new HVAC systems with GWPs >700 on or after January 1, 2026

For Variable Refrigerant Flow (VRF) systems, the regulations prohibit the manufacture and import of HVAC products with GWPs > 700 on or after January 1, 2026.

The phaseout of A1 refrigerants with high GWP has begun.

A2L Refrigerant Codes and Standard

Prior to the 2024 IMC, A2L refrigerants are not recognized for human comfort use. Starting with the 2024 IMC, numerous requirements were added that govern the design and installation of systems using A2L refrigerants including refrigerant charge limits, ventilation requirements, leak detection requirements, and shaft enclosures.

For jurisdictions that have not yet adopted the 2024 I-codes, the ICC has released proposed amendments to the 2021, 2018, 2015 or 2012 I-codes that a jurisdiction could adopt. If your jurisdiction does not adopt these amendments, you may need a code modification to use A2L refrigerants for human comfort.

The 2024 IMC references the 2022 Editions of ASHRAE 15 and 34, both of which provide additional requirements for A2L refrigerants. ASHRAE 34 is the referenced standard for classifying refrigerants. ASHRAE 15 provides a wide range of requirements and is applicable to all A2L refrigerants per IMC 1101.1.1.

In the following sections, we'll review some of the key requirements for A2L refrigerants that could impact your designs.

Shaft Enclosures for A2L Refrigerant Pipes

Perhaps the biggest impact that A2L refrigerants will have on building design is the requirement for shaft enclosures when refrigerant piping penetrates two or more floor/ceiling assembles (IMC 1109.2.5). This code section has had an exception for shaft enclosures for A1 refrigerants where the Refrigerant Concertation Limit (RCL) is not exceeded, but this exception was not extended to include A2L refrigerants. (See below for a potential solution to this challenge based on future code cycles.)

So for most buildings that are three or more stories, rated shafts will be required to protect the pipe risers containing A2L refrigerant. There is another exception to route the piping on the exterior of the building, however this is often undesirable to many building owners due to aesthetic concerns.

Shaft Ventilation for A2L Refrigerant Pipe

If you do elect to run your A2L refrigerant pipes inside the building and a shaft is required, the shaft is required to be naturally or mechanically ventilated (IMC 1109.3.2). If you choose the natural ventilation option, a minimum opening size of 4" in diameter is required at the lowest point of the shaft. If you choose the mechanical ventilation option, the code requires a minimum ventilation velocity based on the area of the shaft and also requires either continuous ventilation or provision of a refrigerant detector to activate the ventilation system.

Refrigerant Detectors for A2L Systems

There are several situations where the IMC requires refrigerant detectors for A2L systems. First, if you are providing A2L refrigerant risers within a shaft and do not want to run the mechanical ventilation system continuously, a refrigerant detector is required (see section above).
If your design includes machinery rooms (see IMC 1104.2 for when required), a refrigerant detector is required per IMC 1105.3.
Note that the provision of a refrigerant detector is also part of two code exceptions in IMC Chapter 11:

As part of an exception to not provide a machinery room in certain industrial occupancies (IMC 1104.2.2)
As part of an exception to not provide a hood and exhaust systems where refrigerants are near and open flame or hot surface (IMC 1104.3.4)

Potential Code Path to Avoid Rated Shafts Using ASHRAE 15

The new requirements described above can pose a challenge to architects and engineers who will have to design buildings with additional rated shafts or plan for the routing of refrigerant linesets on the outside of the building. Fortunately, there are two current (and future) code provisions that provide a strong basis for a code modification request to avoid the rated shaft requirement.

The 2022 Edition of ASHRAE 15, which is referenced by the 2024 IMC, offers the following "Shaft Alternative" options in Section 9.12.15.1:

A shaft enclosure shall not be required for the refrigerant piping for any of the following refrigerating systems:

A) Systems using R-718 (water) refrigerant
B) Piping in high-probability systems where the refrigerant concentration does not exceed the amounts shown in ASHRAE Standard 34, Table 4-1 or 4-2, for the smallest occupied space through which the piping passes
C) Piping located on the exterior of the building where vented to the outdoors

The key focus here is Item b, which allows for the elimination of the shaft for any refrigerant, including A2Ls, when the refrigerant concentration does not exceed the limits found in ASHRAE 34. The similar exception in the 2024 IMC only applies to A1 refrigerants.

While the 2022 ASHRAE 15 is referenced by the 2024 IMC, in situations where the code has a stricter requirement than a referenced standard, the code take precedence. Fortunately, there is a second piece to this code path, a proposed change to the 2027 IMC.

Changes Coming in the 2027 IMC

The 2027 IMC code development process is currently under way. During the 1st Committee Action Hearing (CAH), which took place in April 2024, a code change proposal was submitted for the 2027 IMC to incorporate the same shaft exception that is currently found in the 2022 Edition of ASHRAE 15 (code change proposal M75-24). This proposal was approved unanimously in a 14-0 vote by the IMC committee. The second CAH is scheduled for October 2024, but since there were no comments to the CAH1 ruling, this code change proposal will move directly to the consent agenda for the Public Comment Hearing (PCH). Long story short - the shaft allowance will likely appear in the 2027 IMC.

Using the combination of the ASHRAE 15 allowance plus the coming code change in the 2027 IMC forms a strong technical basis for a code modification to eliminate the rated shaft requirement for A2L refrigerant systems, even if you are seeking permit under one of the older code editions. Ultimately, code modification requests are subject to approval by the AHJ.

If you need assistance pursuing a code modification for this approach, please contact our partners at Campbell Code Consulting for assistance.

Conclusion

The new EPA requirements limiting the manufacture and installation of A1 refrigerants are driving the use of A2L refrigerants in a variety of building types. The use of A2L refrigerants comes with several new code requirements, such as rated, ventilated shafts, which will have a substantial impact on building designs. The use of provisions in the 2022 Edition of ASHRAE 15 and proposed code changes in the 2027 IMC are a strong basis for a code modification request to eliminate the rated shaft requirement.

]]><![CDATA[Code Change Proposal E100 - Horizontal Exits on an Occupied Roof]]>Mon, 30 Sep 2024 04:00:00 GMThttps://www.buildingcode.blog/blog/code-change-proposal-e100-horizontal-exits-on-an-occupied-roofThis post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH).

Code Change Proposal E100 - Horizontal Exits on an Occupied Roof

Link: Code Change Proposal
Link: Hearing Recording

Summary of Code Change
This proposal seeks to allow the provision of a horizontal exit on a 2-hour roof without any rated walls or barriers for separation.

Summary of Testimony and Discussion
There was no testimony in support of the proposal.

Several participants testified in opposition, stating that this proposal did not make sense and that the proposed change was attempting to claim the allowances of a horizontal exit when there was no actual separation provided.

One committee member stated that they have seen this approach taken in the past, but it was part of a detailed alternate methods request and should not be in the model code language.

CAH1 Result
This code change proposal was disapproved by the committee, with a vote of 14-0.

]]><![CDATA[Code Change Proposal E97 - Exit Pathways]]>Fri, 20 Sep 2024 04:00:00 GMThttps://www.buildingcode.blog/blog/code-change-proposal-e97-exit-pathwaysThis post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH).

Summary of Code Change
This proposal involves creating a new component of the means of egress system, entitled an "exit pathway." The proposal defines exit pathways as "An exit component that serves to meet one or more means of egress design requirements and is open to sky." The intent appears to be to allow occupants to enter an interior exit stairway enclosure, then leave that enclosure to walk across a rooftop and then re-entering a different interior exit stairway enclosure.

A schematic of the proposed exit pathway from code change proposal E97.

Summary of Testimony and Discussion

Several participants testified in support of this proposal, stating that this approach is already being taken through a code modification or alternate design process and that it should be explicitly permitted in the code. One person also testified that this approach currently would require an exit passageway across the roof to connect two stair enclosures, but that being open to the sky would actually be a similar level of safety to a rated exit passageway.

Several participants testified in opposition of this proposal, noting that the language needed to be clarified and that current exit discharge requirements need to be addressed in the proposal. There was also discussion of the limitation that exits be used only for egress purposes and that it would be hard to limit a pathway on the roof from being used for other purposes.

CAH1 Result
This code change proposal was disapproved by the committee, with a vote of 13-0.

]]><![CDATA[Code Change Proposal E99 - Rating of Exit Passageways]]>Tue, 03 Sep 2024 04:00:00 GMThttps://www.buildingcode.blog/blog/code-change-proposal-e99-rating-of-exit-passagewaysThis post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH).

Summary of Code Change
This proposal seeks to clarify the required rating for an exit passageway. Essentially, the proposal states that exit passageways have a minimum rating of 1-hour, and then if they are extending from an interior exit stairway or ramp that they have to be not less than the rating of that stairway or ramp.

A schematic of the code clarification from code change proposal E99.

Summary of Testimony and Discussion
The proponent of this proposal stated that the code intent has always been to allow a 1 hour exit passageway prior to entering a 2 hour exit stairway, but that the code has been frequently misinterpreted to require a 2 hour exit passageway any time there is a 2 hour exit stairway.

There was minimal opposition testimony, with one participant stating they just need the proposal language to be clarified.

CAH1 Result
This code change proposal was approved by the committee, with a vote of 14-0.

]]><![CDATA[Updated: An Approach to Mitigating Dead End Corridors]]>Mon, 19 Aug 2024 04:00:00 GMThttps://www.buildingcode.blog/blog/mitigating-dead-end-corridorsFor years, architect clients have asked me for a code solution to solve the challenge of corridors that exceed the dead end limit. As a quick reference, dead ends are limited to 20 feet, except in Groups B, E, F, I-1, M, R-1, R-2, R-4, S and U with a full NFPA 13 sprinkler system, where the limit is increased to 50 feet (2021 IBC 1020.5).

A dead end corridor in a residential building.

Up until recently, my normal suggestion has been to place a cross-corridor door to break up the length of any one corridor segment to less than 50 (or 20) feet. This has been accepted in numerous jurisdictions and also validated by an ICC staff opinion that I requested on the topic. In many cases, I have seen the cross corridor door on magnetic hold opens, to release upon activation of the fire alarm system

Cross-corridor door on magnetic hold opens.

But on a recent project, a local AHJ has taken the stance that a cross corridor door does not mitigate a dead end condition. I scheduled a meeting with the AHJ to explain how this has been done on other projects and to share the ICC interpretation, but they were reluctant to budge. After some negotiations, the AHJ allowed the door, but insisted that it not be held open and also required a large "Not an Exit" sign on the door itself.

I have drawn up a similar situation in the image below. The corridor is serving a Group R-2 occupancy, so the dead end limit is 50 feet.

Sketch showing the dead end condition with added cross-corridor doors.

New Development: An ICC Committee Interpretation

A couple of years after obtaining an ICC Staff Opinion on this matter, I finally decided to request an ICC Committee Interpretation. A Committee Interpretation is developed and approved by the ICC Interpretations Committee and generally carries a little more weight than a lone staff opinion. Fortunately, the Committee Interpretation came back favorably. Check out the language below (or you can view the entire document here).

Yes. The installation of an intervening door within a corridor may be utilized to meet the dead-end corridor maximum length requirements of Section 1020.5. The strategic location of an intervening door, which does not swing in the direction of egress travel and is not provided with exit signage, significantly increases the probability that the occupant will turn around instead of continuing beyond the door into the last section of the dead-end corridor looking for an exit. The placement of the intervening door must be such that each corridor segment on either side of the door is within the dead-end corridor length requirements of Section 1020.5.

Dead End Corridors: What Do You Think?

Do cross-corridor doors mitigate the 20 foot dead end limit? Do you think they should be permitted to be held open?
Let me know your thoughts in the comment box!

]]><![CDATA[Hoistway Opening Protection - An Overview]]>Tue, 06 Aug 2024 04:00:00 GMThttps://www.buildingcode.blog/blog/hoistway-opening-protection-an-overviewOne of the fundamental concepts of fire protection and life safety in a building is compartmentation - the division of a building into multiple compartments to limit the spread of fire and smoke. The provision of floor assemblies, and specifically fire-resistance rated floor assemblies, is one common example of compartmentation. At the same time, there are legitimate reasons to design openings through these floor separation, such as elevator hoistways. To simultaneously allow for elevator hoistways and maintain some level of compartmentation, the International Building Code (IBC) sets forth requirements for protection of hoistway openings. This post will provide an overview of hoistway opening protection, including when it is required and the various options for how to provide the protection. All code references are to the 2021 IBC.

What is Hoistway Opening Protection? (Not Just Elevator Lobbies!)

As alluded to above, hoistway opening protection is a method to protect openings in hoistways in order to limit the spread of fire and smoke. Historically, this protection has been typically provided by enclosed elevator lobbies, but the code does now provide two other methods for this requirement.

It's important to note that most standard elevator doors are already rated 90 minutes per UL 10C. This rating provides protection against fire spread but does not provide any sealed containment against smoke spread. Therefore, in certain cases, the IBC requires additional hoistway opening protection to limit the spread of smoke.

When is Hoistway Opening Protection Required?

The 2021 IBC mandates hoistway opening protection in several scenarios to mitigate the risk of fire and smoke spreading through elevator shafts. Hoistway opening protection is required where an elevator hoistway connects more than three stories and when any of these conditions apply (IBC 3006.2):

The building is not fully sprinkler-protected in accordance with NFPA 13 or 13R.
The building contains a Group I-1, Condition 2 occupancy.
The building contains a Group I-2 occupancy.
The building contains a Group I-3 occupancy.
The building is a high-rise and the hoistway is more than 75 feet in height measured from the lowest floor to highest floor served.

So if a hoistway is connecting more than three stories and meets any of the above conditions, hoistway opening protection is required. There are three exceptions to these requirements:

Hoistway opening protection is not required where the elevator serves only open parking garages.
Hoistway opening protection is not required at the level(s) of exit discharge when those levels are fully sprinkler-protected in accordance with NFPA 13.
Hoistway opening protection is not required on levels where the hoistway opens to the exterior.

Additionally, IBC 3006.2.1 requires hoistway opening protection where hoistways open into a fire-resistance rated corridor.

Other Conditions
There are a number of other code requirements that could require the provision of an elevator lobby:

Underground buildings (IBC 405.4.3)
Areas of refuge (IBC 1009.6)
Fire service access elevators (IBC 3007.6)
Occupant evacuation elevators (IBC 3008.6)

These requirements are only triggered in certain conditions, so be sure to review the above-referenced code sections for more information.

What are the Methods of Hoistway Opening Protection?

The 2021 IBC outlines several methods for protecting hoistway openings, each with its own advantages and specific applications. These methods include (IBC 3006.3):

Elevator Lobby Using Fire Partitions
Elevator Lobby Using Smoke Partitions
Additional Doors at Hoistway Openings
Hoistway Pressurization

Let's delve into each method in detail.

Elevator Lobby - Fire Partitions
Fire partitions are one of the most common methods for hoistway opening protection. Key aspects of this method include:

Fire-Resistance Rating: 1 hour (IBC 708.3)
Continuity: From floor below to underside of floor/roof sheathing above, or to underside of a 1-hour floor or roof/ceiling assembly (IBC 708.4)
Opening Protectives: 20 minute fire door, self-closing unless exceptions are met, smoke/draft control doors not required (IBC 3006.3 and 716.2.2.1)
Duct Penetrations: Fire/Smoke dampers not required if fully ducted system and building is sprinkler protected in accordance with NFPA 13 or 13R (IBC 717.5.4)
Joints/Penetrations: Protected with listed firestop assembly (IBC 714.4)
Impact on Architectural Design: Moderate to high - lobbies take up physical space that could be used for other purposes
Cost Impact: Low - construction of a lobby enclosure is fairly inexpensive

Elevator Lobby - Smoke Partitions
Smoke partitions are similar to fire partitions but focus primarily on preventing the migration of smoke rather than fire. This method includes:

Fire-Resistance Rating: Not required (IBC 710.3)
Continuity: From floor below to underside of floor/roof sheathing above, or to underside of a ceiling assembly that is constructed to limit the transfer of smoke (IBC 710.4)
Opening Protectives: Non-rated doors, self-closing, smoke/draft control doors required (IBC 3006.3 and 710.5.2.2)
Duct Penetrations: Fire/Smoke dampers not required if fully ducted system, smoke dampers required for air transfer openings (IBC 717.5.7)
Joints/Penetrations: Sealed to resist the passage of smoke (IBC 714.6)
Impact on Architectural Design: Moderate to high - lobbies take up physical space that could be used for other purposes
Cost Impact: Low to moderate - construction of a lobby enclosure is fairly inexpensive, however provision and testing of dampers could add to cost

Additional Doors at Hoistway Openings
Installing additional doors at hoistway openings is another method prescribed by the IBC. This approach involves:

Fire-Resistance Rating: Not required (IBC 3006.3)
Continuity: Provided at the hoistway opening only (IBC 3006.3)
Opening Protectives: Non-rated doors, self-closing, smoke/draft control doors (tested without artificial bottom seal) required (IBC 3006.3 and 716.2.2.1.1)
Duct Penetrations: N/A
Joints/Penetrations: N/A
Impact on Architectural Design: Low - as long as there is room to mount the door assembly in or above the hoistway opening, these doors take minimal space
Cost Impact: Moderate to high - these additional doors are typically much more expensive than traditional doors

Hoistway Pressurization
Hoistway pressurization is a more advanced method for protecting hoistway openings. This involves creating a positive pressure differential between the hoistway and the floor to prevent smoke from entering. Hoistway pressurization is considered a smoke control system per IBC 909.21 and requires the following:

Pressure Differential: The system must provide a minimum of 0.1 inches of water and a maximum of 0.25" between the hoistway and the floor (IBC 909.21.1)
Rational Analysis: A rational analysis report complying with IBC 909.4 is required to be submitted with the construction documents (IBC 909.21.2)
Protection: The ductwork and fan system is required to be protected with the same fire resistance rating as required for the elevator shaft itself (IBC 909.21.3 and 909.21.4)
Standby Power: The hoistway pressurization system is required to be provided with standby power (IBC 909.21.5)
Acceptance Testing: Special inspections required (IBC 909.18.8)
Ongoing Testing: Required semiannually for dedicated systems (IFC 909.22.4)
Impact on Architectural Design: Low - hoistway pressurization fans can typically be located on the roof
Cost Impact: High - the cost to design and install pressurization systems is often more than the other protection methods

Comparing Hoistway Opening Protection Methods

While each method of hoistway opening protection has advantages and disadvantages, here are my recommendations:

If you are going with a lobby, use the method which does not require a damper. From a construction standpoint, a 1 hour rated fire partition and a smoke partition are fairly similar. However, the provision of fire and/or smoke dampers adds additional cost and testing requirements that can be avoided.
If no lobby, utilize additional doors at the hoistway. While these additional doors at the hoistway opening can be expensive, they are fairly easy to design, test and maintain. The other option, hoistway pressurization, is considered a smoke control system and comes with substantial requirements both for design and ongoing maintenance.

Conclusion

The IBC offers four methods for hoistway opening protection: elevator lobbies using either fire partitions or smoke partitions, additional doors at the hoistway openings, or hoistway pressurization. This protection is required in certain instances, depending on the occupancy, presence of sprinklers and height of the building, but is only necessary for hoistways connecting more than three stories or opening onto a rated corridor.

]]><![CDATA[Code Change Proposal E109 - Remoteness of Exit Discharge]]>Thu, 18 Jul 2024 04:00:00 GMThttps://www.buildingcode.blog/blog/code-change-proposal-e109-remoteness-of-exit-dischargeThis post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH).

Code Change Proposal E109 - Remoteness of Exit Discharge

Link: Code Change Proposal
Link: Hearing Recording

Summary of Code Change
This proposal involves taking the existing exit remoteness requirements for exit and exit access doorways (typically one-half or one-third of the diagonal of the area served) and adding those requirements to the exit discharge. The proposal would prevent exit discharge doors from being located close to each other.

Summary of Testimony and Discussion
The proponent of this proposal testified that exit discharge points located too close together could result in a situation where a single fire event blocked the discharge of both exits in a two-exit building, resulting in an unsafe situation.

Several participants testified in opposition of this proposal, noting that they believed it was overly restrictive and that the exit discharge was an inherently safer location that should not require such separation. A participant also noted that this would be extremely difficult to measure and arrange in a building with many exits.

CAH1 Result
This code change proposal was disapproved by the committee, with a vote of 14-0.

]]><![CDATA[Code Change Proposal E110 - Exit Discharge Through a Lobby Using Signage]]>Tue, 09 Jul 2024 04:00:00 GMThttps://www.buildingcode.blog/blog/code-change-proposal-e110-exit-discharge-through-a-lobby-using-signageThis post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH).

Code Change Proposal E110 - Exit Discharge Through a Lobby Using Signage

Link: Code Change Proposal
Link: Hearing Recording

Summary of Code Change
This proposal involves a three word modification to IBC 1028.2 Exception 1. The current code language for this section allows not more than 50% of exit stairways to discharge through areas on the level of exit discharge when a number of conditions are met.

The key condition at play here is that "Discharge of interior exit stairways and ramps shall be provided with a free and unobstructed path of travel to an exterior exit door and such exit is readily visible and identifiable from the point of termination of the enclosure."

The code change proposal seeks to add "by exit signage" after the "readily and identifiable" clause.

Summary of Testimony and Discussion
The testimony for this code change proposal involved a desired alignment with NFPA 101, which already allows exit discharge through a lobby using exit signage and does not explicitly require a clear line of site from the stairway to the exterior exit door. A point about distance limitations was brought up, but this code change proposal does not include any distance limits between the exit stair and the exterior exit door (it was noted by participant testimony that the overall exit travel distance requirement would still apply on the floor).

This proposed change would no longer require a clear line of site between the stair door and door to the exterior, but will now require that the door to the exterior be readily visible and identifiable by exit signage.

CAH1 Result
This code change proposal was approved by the committee, with a vote of 13-0.

]]><![CDATA[Code Change Proposal E112 - Exit Discharge onto Roof or Podium]]>Mon, 24 Jun 2024 04:00:00 GMThttps://www.buildingcode.blog/blog/code-change-proposal-e112-exit-discharge-onto-roof-or-podiumThis post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH).

Please note that I am serving on the 2024-2026 IBC Egress Committee, so many of the articles in this series will be egress-related. Each post is my attempt to summarize the code change proposal and the presentation/discussion from CAH1, but please refer to the links below that include the actual code change proposal language and the CAH1 recording. These posts are not intended to provide my personal opinion or commentary on the code changes.

Code Change Proposal E112 - Exit Discharge onto Roof or Podium  

Link: Code Change Proposal
Link: Hearing Recording

Summary of Code Change

This proposal involves a new allowance in IBC 1028.2 to allow exit discharge onto the roof of a building or onto a horizontal building separation (podium) per IBC 510.2 when certain conditions are met:
- The exit discharge has a free and unobstructed path of travel that is readily visible and identifiable
- The exit discharge does not include re-entering the building or utilizing an interior exit stairway/ramp or exterior exit stairway/ramp
- The structural bays of the roof assembly that support the exit discharge path contain no unprotected openings and have a fire-resistance rating not less than the exit enclosure that discharge onto the roof, or not less than one hour

Summary of Testimony and Discussion
The proponent of this proposal testified that this code change addresses a common situation in building design, where a building exit discharge to a space that is outdoors but above the roof of the building (for example, a building that has below grade parking that extends beyond the footprint of the building above grade). The proponent noted that the proposal requires the roof assembly to have the same rating as the exit enclosure itself, thereby providing an equivalent level of protection.

One participant testified in opposition of this proposal, noting that they believed the roof of a building could not be considered exit discharge and that this proposal needed to be relocated to a different portion of the code.

The committee had a number of back and forth comments on this proposal. One committee member felt that this approach should not be directly allowed by the code but should be handled on a case-by-case basis through a code modification or variance process. I commented during the hearing that I have seen this approach taken on multiple buildings and voted in support of the proposal. I also noted that when this approach is used on an IBC 510.2 podium building, occupants would have atleast a 3 hour rated horizontal assembly beneath them and would be open to the sky, resulting in a fairly high level of protection.

CAH1 Result
This code change proposal was approved by the committee, with a vote of 8-6.

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What is a Portable Fire Extinguisher

Classifying Fire Hazards and Selecting the Right Extinguisher

Where Are Fire Extinguishers Required

Extinguisher Size, Distribution, and Rating

Class A Fire Hazards

Class B Fire Hazards

Class C Fire Hazards

Class D Fire Hazards

Cooking Equipment Fires

Installation Requirements and Guidelines

Conclusion

What is a High-Rise Building?

Construction Type and Fire Resistance Ratings

​Structural Integrity

​Fire Sprinkler Systems

​Fire Alarm and Smoke Detection Systems

Fire Department Response

Egress and Stairway Design

Elevator Requirements

Emergency Power and Fire Command Center

Conclusion

Free High Rise Code Requirements Cheat Sheet

Horizontal Exit Code Requirements

Horizontal Exit Egress Capacity

Horizontal Exit Refuge Area

Horizontal Exit Standpipe Hose Connections

Is an opening in a fire wall automatically a horizontal exit?

​Icing on the Cake: An ICC Committee Interpretation

Conclusion

Revolving Doors

Manual Revolving Doors​Max Door Speed

Auto/Power Revolving DoorsMax Door Speed

Power-Operated Doors

​Special Purpose Horizontal Sliding, Accordion or Folding Doors

​Locking Arrangements in Educational Occupancies

​Security Grilles

​Group I-1 and I-2 Controlled Egress Doors

Delayed Egress

​Sensor Release of Electrically Locked Doors

​Electromagnetically Locked Doors

​Door Hardware Release of Electrically Locked Doors

​Correctional Facilities

​Stairway Doors

​Panic and Fire Exit Hardware

Elevator Lobby Exit Access Doors

Conclusion

What are A2L Refrigerants?

What Federal Regulations are Driving A2L Refrigerants

A2L Refrigerant Codes and Standard

Shaft Enclosures for A2L Refrigerant Pipes

Shaft Ventilation for A2L Refrigerant Pipe

Refrigerant Detectors for A2L Systems

Potential Code Path to Avoid Rated Shafts Using ASHRAE 15

Changes Coming in the 2027 IMC

Conclusion

New Development: An ICC Committee Interpretation

Dead End Corridors: What Do You Think?

What is Hoistway Opening Protection? (Not Just Elevator Lobbies!)

When is Hoistway Opening Protection Required?

What are the Methods of Hoistway Opening Protection?

Comparing Hoistway Opening Protection Methods ​

Conclusion

Code Change Proposal E109 - Remoteness of Exit Discharge

Code Change Proposal E112 - Exit Discharge onto Roof or Podium ​

Structural Integrity

Fire Sprinkler Systems

Fire Alarm and Smoke Detection Systems

Icing on the Cake: An ICC Committee Interpretation

Manual Revolving Doors
Max Door Speed

Auto/Power Revolving Doors
Max Door Speed

Special Purpose Horizontal Sliding, Accordion or Folding Doors

Locking Arrangements in Educational Occupancies

Security Grilles

Group I-1 and I-2 Controlled Egress Doors

Sensor Release of Electrically Locked Doors

Electromagnetically Locked Doors

Door Hardware Release of Electrically Locked Doors

Correctional Facilities

Stairway Doors

Panic and Fire Exit Hardware

Comparing Hoistway Opening Protection Methods

Code Change Proposal E112 - Exit Discharge onto Roof or Podium  