This 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 E99 - Rating of Exit Passageway 
Link: Code Change Proposal  
Link: Hearing Recording  

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. 

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.  

​For 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).

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. ​

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): 

1. The building is not fully sprinkler-protected in accordance with NFPA 13 or 13R. 
2. The building contains a Group I-1, Condition 2 occupancy. 
3. The building contains a Group I-2 occupancy. 
4. The building contains a Group I-3 occupancy. 
5. 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: 

1. Hoistway opening protection is not required where the elevator serves only open parking garages. 
2. 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. 
3. 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: 

1. Underground buildings (IBC 405.4.3) 
2. Areas of refuge (IBC 1009.6) 
3. Fire service access elevators (IBC 3007.6) 
4. 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. ​

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

1. Elevator Lobby Using Fire Partitions 
2. Elevator Lobby Using Smoke Partitions 
3. Additional Doors at Hoistway Openings 
4. 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 barriers 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 ​

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. ​

This 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. 

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.  

​This 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 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. 

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. 

Welcome to a new blog series, where over the next couple of months, I will 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.

Link: Code Change Proposal
Link: Hearing Recording

Summary of Code Change
This proposal involves a modification to IBC Section 1006 to allow a single exit in Group R-2 buildings up to six stories when several conditions are met, including:

• A limit to the number of dwelling units per story, complying with one of the following:
  • Basement through sixth story limited to 4 dwelling units served per exit on each story OR
  • Basement through third story limited to 6 dwelling units served per exit on each story
• Limited to buildings of Type IA, IB, IIA or IV construction
• Travel distance limit of 125 feet
• Travel distance limit from the unit door to the stairway of 25 feet
• 2 Hour exit enclosure
• Interior exit stairway designed as a smokeproof enclosure
• Emergency escape and rescue openings provided

Summary of Testimony and Discussion
The testimony for this code change proposal was intense! Dozens of people appeared to testify and the overall time spent, including testimony and committee action was over an hour. The proponent of this proposal seemed to be motivated primarily by a need for affordable housing, claiming that the requirement for a second exit stairway in certain residential buildings drives costs and makes development of some residential buildings infeasible.
 
The opposition testimony to the proposal included a wide variety of perspectives. Many participants cited the life safety risk for both building occupants and first responders. Others stated that such a code change was inappropriate at the national level and should be left to state and local jurisdictions to amend the code as needed. Several participants brought up the cost to install and maintain a smokeproof enclosure for the stairway, as well as the added cost of providing standby power for such systems.

CAH1 Result
After extensive testimony and discussion, this code change proposal was disapproved by the committee, with a vote of 14-0.
 
Note that a similar code change proposal, E25, was also submitted, to allow the same single exit arrangement in Group R-1 occupancies. This code change proposal was also disapproved by the committee, with a vote of 14-0.

If you have ever worked on the design of a high-rise building, you almost certainly have come across a stairway pressurization system. Fans located on the roof, a shaft next to the stair, extra ductwork – all are common in high-rise design. But even though nearly all high-rise buildings have these systems, there are many wide-spread misconceptions and misunderstanding about stair pressurization.

For example, did you know that stairway pressurization is not actually required by the IBC?
​
What?!?

Or did you know that there is a detailed analysis that must be conducted as part of the stair pressurization design process?
In this article, we will dispel some of these common misconceptions and misunderstandings about stair pressurization systems.

​If you are working on a project in Prince George's County, MD or in Rockville, MD, you may have had a last minute scare on a project, where you learned that a Fire Protection Engineering Design Evaluation Report (FPEDE) was required. 

In this article, we'll discuss what and FPEDE is, when it is required, and how you can obtain one for your project.

If you already know you need an FPEDE for your project, our friends at Campbell Code Consulting can help you. Click here to contact them directly.

Update: Now includes cheatcheets for the 2021 and 2024 IBC

After way too many hours of work, I'm excited to share this huge fire and smoke damper cheatsheet that goes through EVERY instance where the 2018 IBC requires a fire and smoke damper due to a wall/floor/ceiling penetration.