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The Building Code Blog

Stairway Code Requirements - An Overview

1/25/2023

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​Key Takeaway: The IRC and IBC both provide a variety of requirements for stairways and staircases, including minimum width, minimum and maximum riser/tread dimensions, minimum headroom height and maximum total rise.
A stairway is a key part of the means of egress for any multi-story building or structure. Also known as a stair or staircase, stairways provide a path for occupants to traverse from one level to another within a building or space. In this post, we’ll review some of the key requirements for stairways from both the International Residential Code (IRC) and the The International Building Code (IBC). All references are to the 2021 editions of these codes.
An interior open stairway.
An interior open stairway.

What is a Stairway?

There are two key definitions here that are important to understand: Stair and Stairway. Both the IRC and IBC defines these terms as follows:
​

Stair: “A change in elevation, consisting of one or more risers.”

Stairway: “One or more flights of stairs, either exterior or interior, with the necessary landings and platforms connecting them, to form a continuous and uninterrupted passage from one level to another.”

So a stair is simply the change in elevation that is created by one or more risers, while a stairway includes both the stairs and the required landing and platforms. Note that the term “staircase” is frequently used when referring to a stairway, but neither code actually uses this term. If you are working on a project that contains an unenclosed stairway (also known as an open stairway), be sure to check out this post on additional requirements.

Minimum Width for IRC Stairways (R311.7)

For projects falling under the IRC, the minimum stair width is 36 inches. The minimum width must be provided at all points above the permitted handrail height and below the required headroom height (meaning walls or other protruding objects cannot decrease this minimum width).

Any provided handrails cannot protrude more than 4.5 inches into the minimum width. So if a handrail is provided on one side, the minimum clear width is 31.5 inches and if a handrail is provided on both sides, the minimum clear width is 27 inches.

Note that the following stairways are not required to meet the minimum width requirements:
  • Stairways not within or serving a building, porch or deck.
  • Stairways leading to nonhabitable attics.
  • Stairways leading to crawl spaces.
  • Spiral stairways, which have separate minimum width requirements in R311.7.10.1
Stair width and handrail requirements from the 2021 IRC.
Stair width and handrail requirements from the 2021 IRC.

Minimum Width for IBC Stairways (1011.2)

For projects falling under the IBC, there are two width requirements that apply: minimum width and required capacity.

Generally, the minimum stair width is 44 inches, unless the stairway serves an occupant load of less than 50, in which case the minimum width is 36 inches. Note that if the stairway is serving as an accessible means of egress, the minimum width between handrails is 48 inches, unless the building is fully sprinkler-protected or the stairway is provided with an area of refuge. Check out this article for more information on the required means of egress vs. accessible means of egress.

Note that the following stairways are not required to meet the minimum width requirements:
  • Spiral stairways, which have separate minimum width requirements in 1011.10
  • Where an incline platform lift or stairway chairlift is installed on stairways serving occupancies in Group R-3, or within dwelling units in occupancies in Group R-2, a clear passage width not less than 20 inches is required. Where the seat and platform can be folded when not in use, the distance must be measured from the folded position.

The second width requirement is the required egress capacity of the stairway (IBC 1005.3.1). The required capacity is determined by multiplying the occupant load using the stairway by a capacity factor of 0.3 inches per occupant. In other than Group H and Group I-2 occupancies, this factor is reduced to 0.2 inches per occupant when the building is fully sprinkler-protected and equipped with a voice fire alarm system. There are also reductions available for open-air or smoke-protected assembly seating spaces.

Note that for multi-story buildings, only the occupant load of each individual story is considered when calculating the required capacity for each stair, not the cumulative occupant load using the stair.

Similar to the IRC, the IBC allows handrails to project a maximum of 4.5 inches into the required width. So for a stair with handrails on each side that has a minimum required width of 44 inches, the minimum width between handrails would be 35 inches.

Handrail Height

In both the IRC and IBC, handrails are required to be located a minimum of 34 inches and a maximum of 38 inches above the stair. Specifically, this dimension is measured vertically from the stair tread nosing.

Note that when handrails are transitioning between flights or at the start of a stairway, the fitting and bendings are permitted to exceed the maximum height.
Stair width and handrail requirements from the 2021 IBC.
Stair width and handrail requirements from the 2021 IBC.

Stair Treads and Risers (R311.7.5)

For projects falling under the IRC, the minimum tread depth is 10 inches, plus a required nosing of at least ¾ inch. If a tread of at least 11 inches is provided, there is no required nosing. The maximum permitted nosing is 1.25 inches. In any stairway, the tread depth and nosing depth have a maximum permitted variation of ⅜ inch. Note that under the IRC, the tread depth is measured horizontally between the vertical planes of the foremost projection of adjacent treads and at a right angle to the tread's leading edge.

The maximum riser height is 7.75 inches, with a similar maximum permitted variation of ⅜ inch in any single stairway. Risers must be vertical or have a maximum slope of 30 degrees from vertical.
Stair dimensional requirements from the 2021 IRC.
Stair dimensional requirements from the 2021 IRC.

Stair Treads and Risers (1011.5.2)

For projects falling under the IBC, the minimum tread depth is 11 inches. There is no requirement to provide a nosing, but the maximum nosing projection is 1.25 inches. Note that under the IBC, the tread depth is measured horizontally between the vertical planes of the foremost projection of adjacent treads and at a right angle to the tread's nosing.

The IBC requires stairs to have a minimum riser height of 4 inches and a maximum height of 7 inches.

Note that the following stairways are not required to meet the minimum riser/tread requirements:
  • Spiral stairways, which have separate dimensional requirements in 1011.10
  • Stairways connecting stepped aisles to cross ailes or concourses, which have separate dimensional requirements in 1030.14.2.
  • Stairways in Group R-2 dwelling units and Group R-3 occupancies, which have separate requirements given in 1011.5.2.
  • Replacement of existing stairs, which is governed under the International Existing Building Code (IEBC)
Stair dimensional requirements from the 2021 IBC.
Stair dimensional requirements from the 2021 IBC.

Headroom Requirements

Both the IRC and IBC have similar requirements for headroom clearance. In both codes, the minimum headroom clearance is 80 inches, measured vertically from a line connected to the edge of each nosing. 

Both codes have exceptions for spiral stairways and where the nosings of treads at the side of a flight extend under the edge of a floor opening through which the stair passes (limited to Group R-2 dwelling units and Group R-3 in the IBC).

Vertical Stairway Rise

Under the IRC, a single flight of stairs can have a maximum vertical rise of 12 feet 7 inches between floor levels or landings (R311.7.3). Under the IBC,the maximum rise is 12 feet (1011.8).

Summary

The requirements for stairways depend on whether your project falls under the IRC or IBC.

For IRC Stairways:
Minimum Width = 36”
Maximum Handrail Projection = 4.5” each side
Minimum Tread Depth = 10”
Minimum Nosing = ¾” or provide 11” tread
Maximum Nosing = 1.25”
Maximum Riser Height = 7.75”
Minimum Headroom = 6’-8”
Maximum Stairway Rise = 12’-7”

For IBC Stairways:
Minimum Width = 44” or 36” for smaller occupant loads. See also required capacity requirements.
Maximum Handrail Projection = 4.5” each side
Minimum Tread Depth = 11”
Minimum Nosing = Not Required
Maximum Nosing = 1.25”
Minimum Riser Height = 4”
Maximum Riser Height = 7”
Minimum Headroom = 6’-8”
Maximum Stairway Rise = 12’
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Egress Windows - Sizing and Requirements Explained!

1/10/2023

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Key Takeaway: Egress windows are required in all sleeping rooms for projects falling under the IRC and in many sleeping rooms for projects falling under the IBC. When required, the openings must meet specific egress window sizing requirements, and when provided below grade, must open into an area well.
If you are working on a residential design or construction project, an important design consideration is the requirement for egress windows. While most people in the design community understand what you are referring to with this term, “egress windows” is not actually defined in the code. The International Building Code (IBC) and International Residential Code (IRC) both refer instead to Emergency Escape and Rescue Openings (EEROs).
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In this article, we’ll refer to egress windows and EEROs interchangeably, but remember that the code only defines EEROs. A window can be used to meet the EERO requirements, but doors and other openings are also an option. All references are to the 2021 IBC and IRC.
A basement emergency escape and rescue opening (egress window).
A basement emergency escape and rescue opening (egress window).

What is an Egress Window?

Egress Windows, or as the code calls them, EEROs, are defined in the IBC as “an operable exterior window, door or other similar device that provides for a means of escape and access for rescue in the event of an emergency.

Essentially, an egress window or EERO is a way for a building occupant to escape in the event of an emergency or for a first responder or other personnel to access a building for the purposes of rescue. A fire is the obvious emergency that comes to mind, but the openings could be used for any emergency situation.

When are Egress Windows Required?

If you are working on a residential project in the United States, your building likely falls under one of two codes: the International Building Code or the International Residential Code. While the adoption of these codes varies by State and local jurisdiction, generally the IBC applies to apartments and larger residential facilities while the IRC applies to one and two family dwellings and townhouses. Many jurisdictions amend these codes, so be sure to check the applicable code enforced by your local authority having jurisdiction.

IBC Requirements

If your project falls under the IBC, emergency escape and rescue openings are required in the following occupancies (IBC 1031.2):
  • Group R-2 occupancies located in stories with one one exit or access to only one exit
  • Group R-3 and R-4 occupancies

If you meet either of these conditions, then the IBC requires you to provide emergency escape and rescue openings in any basement or sleeping room below the fourth story above grade plane. There are numerous exceptions where EEROs would not be required:
  • Basements with a ceiling height of less than 80 inches
  • Basements or sleeping rooms with an exit or exit access door opening directly into a public way, yard, or court. This exception would also apply if the door opens onto an exterior egress balcony that opens to a public way.
  • Basements less than 200 square feet in floor area with no habitable spaces
  • Storm shelters complying with ICC 500
  • In fully sprinklered Group R-2 and R-3 buildings, individual dwelling/sleeping units located in a basement are not required to have EEROS when the basement as a whole has one means of egress and one EERO or two means of egress.​

You can also check out a past blog post regarding how certain code officials interpret this IBC requirement.

IRC Requirements

If your project falls under the IRC, Emergency Escape and Rescue Openings are required in basements, habitable attics and every sleeping room. If the basement contains more than one sleeping room, an EERO is required in each sleeping room (IRC 310.1).
​

There are numerous exceptions where EEROs would not be required:
  • Storm shelters and basements used only to house mechanical equipment not exceeding a total floor area of 200 square feet
  • In fully sprinklered buildings, sleeping rooms located in a basement are not required to have EEROS when the basement as a whole has one means of egress and one EERO or two means of egress.

Egress Window Sizing Requirements

Both the IBC and IRC have the same dimensional sizing requirements for EEROs:
  • Minimum of 5.7 square feet of net clear opening area
  • Minimum of 24 inches of net clear opening height
  • Minimum of 20 inches of net clear opening width
There is an exception that the minimum net clear opening area for grade-floor EEROs is 5 square feet.
Dimensional requirements for emergency escape and rescue openings.
Dimensional requirements for emergency escape and rescue openings.
These dimensions are required to be a result of the normal operation of the window or door - you cannot break or alter the window/door in order to achieve the required dimensions.

Basement Egress Windows

Area wells are required to be a minimum of 9 square feet in area with a minimum dimension of 36 inches in both length and width. The area well must also be of sufficient size to allow the EERO to fully open.

If the area well has a depth of more than 44”, a ladder or steps are required. The egress window or door opening into the area well cannot obstruct the ladder or steps when fully open. 
PictureDimensional requirements for area wells.
Dimensional requirements for area wells.
If you choose to provide a ladder for the area well, the ladder must have an inside width of at least 12 inches, must project at least 3 inches from the area well wall and the ladder rungs must be spaced no more than 18 inches apart for the entire height of the area well.

If you choose to prove steps for the area well, the steps must have a minimum width of 12 inches, a minimum tread depth of 5 inches and a maximum riser height of 18 inches for the entire height of the area well.

Finally, area wells are required to be connected to the buildings foundation drainage system unless the building is located on well-drained soil or sand-gravel mixture soils as defined by IBC 1803.5.1 and IRC 405.1

Bars, Grilles, Covers and Screens over Egress Windows

When bars, grilles, covers, screens or other similar devices are placed over EEROs or area wells, these devices cannot reduce the minimum required dimensions described above. Additionally, the bar, grilles, cover or screen must be releasable or removable from the inside without a key or tool and cannot require a greater force than what is required to open the EERO itself.

Summary

​Egress windows, which the code refers to as “Emergency Escape and Rescue Openings” (EEROs) are required in all sleeping rooms for projects falling under the IRC and in many sleeping rooms for projects falling under the IBC.
​

When required, EEROs must meet the following size requirements:
  • Minimum of 5.7 square feet of net clear opening area
  • Minimum of 24 inches of net clear opening height
  • Minimum of 20 inches of net clear opening width

If the EERO is below grade level, a minimum 36” x 36” area well is required. If the area well is more than 44” deep, a ladder or steps are required.

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Does an Occupied Roof Trigger High-Rise Requirements?

11/11/2022

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**Updated 11/11/2022 with final ICC results and an updated cheatsheet.

This week, the ICC Committee Action Hearings (CAH) kicked off, where proposed code changes for the 2024 ICC Codes are heard by the various ICC committees. In yestereday's session, the IBC General committee heard several proposed changes related to occupied roofs and the classification of high-rise buildings. In recent code cycles, there have been several key changes to occupied roof requirements, but none of these have addressed whether an occupied roof over 75' would trigger classification of a high-rise building.

As a quick reminder, the 2021 IBC currently defines a high-rise building as "A building with an occupied floor located more than 75 feet above the lowest level of fire department vehicle access."
Picture
If the current proposed code change moves forward, an occupied roof like this one could trigger classification as a high-rise building.
While previous code editions have remained silent on the issue, the ICC website does have two articles addressing high rise classification due to an occupied roof.

This article, authored by ICC staff member Chris Reeves, clearly states that an occupied roof is not intended to count as a floor for the purposes of evaluating the high-rise building definition. Another article, authored by ICC staff member Kimberly Paarlberg, states "What has not yet been clarified is if an occupied roof is considered an occupied floor when determining if the building does or does not have to meet the high-rise provisions in the code..."

While the two articles above are both informal opinions from ICC staff, it appears the 2024 IBC will now address this issue directly. During today's hearing, the IBC General Committee voted in favor of proposal G15-21, which is copied below:

Revise as follows:
[BG] HIGH-RISE BUILDING. A building with an occupied floor or occupied roof located more than 75 feet (22 860 mm) above the lowest level of fire department vehicle access.

This proposed change to the definition of a high-rise building would require any building with an occupied roof above 75' to meet all of the high-rise building requirements.  Several proposals, including G12-21 and G14-21, were aimed the other way, attempting to clarify that an occupied roof would not trigger a high-rise classification. Both of these were disapproved by the committee.

When a building is classified as a high-rise, there are numerous additional requirements, including:
  • Hard Body Impact requirements for stairway and hoistway walls in Risk Category III and IV buildings (IBC 403.2.3)
  • Minimum SFRM bond strength of 430 psf (up to 1,000 psf for buildings higher than 420') (IBC 403.2.4)
  • Voice fire alarm system (IBC 403.4.4)
  • Fire command center (IBC 403.4.6)
  • Smoke removal (IBC 406.4.7)
  • Additional standby and emergency power requirements (403.4.8)
  • Smokeproof enclosures (most commonly stair pressurization) for exit stairways (IBC 403.5.4)

    IBC High Rise Building Requirements Cheatsheet

    Enter your name and email below to get a free cheatsheet that summarizes the code requirements for High-Rise Buildings.
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What Do You Think?

Do you agree with the General Committee on this issue? Should an occupied roof above 75' trigger the classification as a high rise building? Please share your thoughts in the comments section!

Update 11/11/2022:

This proposed change has been approved and will be included in the 2024 IBC.
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Is an Opening in a Fire Wall Automatically a Horizontal Exit?

10/27/2022

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In projects of Type II, III, IV or V construction, architects are often forced to balance the allowable area limits of lesser construction types and 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 structure 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 review 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?
Picture
A pair of opposing doors in a fire wall.
Before I get to my answer, you might be asking: why does this matter?

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

Exit 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 can not be providing 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.​

Refuge Areas

​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 accommodate the original occupant load of the space plus 3 square feet for 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.​

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.
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Code Requirements for Dryer Vents/Exhaust Ducts in Multi-Family Residential Buildings

10/3/2022

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​I work on a variety of multi-family housing projects, including residential apartment buildings and senior living facilities, where each dwelling unit has its own washer and dryer. In the past, I have always seen the dryer exhaust duct routed through a wall and then into the cavity of a floor-ceiling assembly, but on a recent project, the local AHJ questioned the validity of this approach. 

Code Requirements for Dryer Vent Installation

This post is a summary of the code requirements and my suggestions for the most straight-forward way to handle the situation. All code references are the 2021 ICC Codes.

Challenge 1: No Dampers Permitted

The first challenge when approaching dryer exhaust ducts is that the International Mechanical Code (IMC) Section 504.2 specifically prohibits the installation of fire dampers or combination fire/smoke dampers.
​
If your dryer exhaust duct does not penetrate a rated wall or floor assembly, then you likely have no issue. However, since no one wants to look at a dryer exhaust duct running through their apartment, most designers choose to route the duct into the ceiling and then out of the building. This leads us to challenge 2.

Challenge 2: Dampers Required at Floor/Ceiling Penetrations

A duct that penetrates the ceiling of a floor/ceiling assembly and then runs horizontally through the floor cavity and out of the building would be considered a membrane penetration.

IMC Section 607.6.2 requires that duct membrane penetrations of a rated floor/ceiling or roof/ceiling assembly be protected with either a listed ceiling radiation damper or a shaft enclosure (there is a similar requirement in IBC Section 717.6.2).
​
We already know from our first challenge that a damper is not permitted, so that seemingly leaves a shaft enclosure as the only option. Again, it’s undesirable to building residents or designers to have a shaft enclosure simply to protect a dryer exhaust duct.

Solution: Dryer Vent Installation

Fortunately, a straight-forward solution is found in IBC 717.6.2.2, Exception 2.

The exception here allows for the omission of a damper at the ceiling membrane penetration when the duct is protected in accordance with IBC Section 714.5.2, is located within the cavity of a wall and does not pass through another dwelling unit or tenant space.

Our situation meets the last two requirements, as the duct is first routed into a wall prior to running through the ceiling cavity, where it then is routed horizontally to the exterior, without passing through another dwelling unit. For the first requirement, IBC Section 714.5.2 states that membrane penetrations of horizontal assemblies must comply with 714.5.1.1 or 714.5.1.2, which give requirements for through-penetration firestop systems. This section also offers 8 different exceptions.
Picture
Detail showing the membrane penetration permitted by IBC 717.6.2.2, Exception 2.
Before we get into those exceptions, though, it’s important to point out that running the dryer exhaust duct through a wall and into the ceiling cavity presents us with another code question: how do we address the intersection of the wall and rated floor/ceiling assembly?

If the top of the wall is located completely below the ceiling membrane of the rated floor/ceiling or roof/ceiling assembly, there is no issue. However, this arrangement is difficult to construct, particularly in wood construction, as it would require a continuous ceiling running past the top of the wall.

Most of the time, the top of the wall interrupts the ceiling membrane, meaning the ceiling stops on one side of the wall and continues on the other side. This arrangement would itself be considered a membrane penetration of the floor-ceiling or roof-ceiling assembly, even without a dryer duct present. IBC Section 714.5.2 Exception 7 addresses this exact situation:
The ceiling membrane of a maximum 2-hour fire-resistance-rated horizontal assembly is permitted to be interrupted with the double wood top plate of a wall assembly that is sheathed with Type X gypsum wallboard, provided that all penetrating items through the double top plates are protected in accordance with Section 714.5.1.1 or 714.5.1.2 and the ceiling membrane is tight to the top plates.”
This exception allows for the wall to interrupt the ceiling membrane as long as it is provided with a double wood top-plate that is tight to the ceiling and sheathed with Type X gypsum board. Note that this section does not require the wall to be rated.

Additionally, the exception requires that the duct be protected in accordance with Section 714.5.1.1 or 714.5.1.2 (the same through penetration firestop sections referenced earlier).

For my specific project, the building is a wood-framed structure, so there was no issue in providing a double top plate for each wall. In buildings of Type I or II construction, this would still be a valid approach as long as the wall itself is not a bearing wall and fire-retardant treated wood is used for the double top plate (IBC Section 603.1, Item 1.1).

The final code section here, IBC Section 714.5.1.2, requires an approved through penetration firestop system with F and T ratings of at least 1 hour but not less than the rating of the floor itself. Exception 1 of this section eliminates the requirement for the T rating when the penetration is located within the cavity of a wall.

This requirement forces us to find a listed fire-stop assembly that matches out proposed conditions. There are numerous assemblies available, particularly through companies such as Hilti or 3M.
​
If you are tracking the code path through the mechanical code, the path is shorter, but the end result is the same. IMC Section 607.6.2, Exception 2 allows for the omission of a damper at the ceiling membrane penetration when the duct is protected in accordance with IBC Section 714.5.1.2, is located within the cavity of a wall and does not pass through another dwelling unit or tenant space. Note the subtle difference in section here compared to IBC Section 717.6.2.2 Exception 2 – the IMC takes you directly to the through penetration firestop requirement.

See the flow chart below comparing the code path through both the IBC and IMC.

Picture
Comparison of the IBC and IMC code paths.

Potential Challenge with Firestop System

On the recent project where this issue came up, every firestop assembly for this configuration that I found stated that the dryer duct could be located within a wall, but when the wall was used, it had to be a minimum 1-hour rated wall. This was a challenge because the proposed configuration for my project involved the dryer exhaust duct running through an interior dwelling unit wall which was not rated.
​
After a few hours of digging through the UL firestop database, I could not find a single listed firestop system that described a duct running through a non-rated wall and then into a 1-hour floor/ceiling assembly. This was a surprising result, as the IBC clearly does not require the wall to be rated when using Section 714.5.2 Exception 7. I ended up pursuing an Engineering Judgment to address the situation.

Conclusion

​Both the IBC and IMC provide code paths to route a dryer exhaust duct through wall, into a rated floor/ceiling or roof/ceiling assembly, and then out of the building. A listed firestop assembly is required to address the penetration of the duct through the ceiling membrane. If you happen to be running your duct through a rated wall, there are numerous firestop assemblies readily available for this configuration. If you are running the duct through a non-rated wall, you will likely need an engineering judgement. If you have found a listed firestop assembly that allows for a non-rated wall in this scenario, please let me know!
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International Existing Building Code: Does it Apply to My Existing Building?

3/30/2022

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As I have spent time in existing buildings over the years, whether surveying a building for potential renovations, reviewing existing conditions or doing inspections, the concept of the building “meeting code” often comes up. Building owners, building maintenance staff, or anyone that is concerned with the operation or maintenance of a building wants to know if their building is up to code. Unfortunately, “meeting code” can mean several different things, and it is easy to lose track of which codes actually apply to an existing building. Does the International Building Code apply? Or is the International Existing Building Code? Or both?
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In this post, we’ll explore the various building and fire codes that could apply to your existing building. There are many other codes (e.g. electrical, elevator) that we won’t specifically address, but the general thought process for those is similar. All references will be to the 2021 ICC codes, but many states and local jurisdictions modify these requirements, so be sure to verify the specific requirements for your area.

Note: If your building is a one or two family dwelling or a townhouse, the International Residential Code (IRC) is likely the applicable code. The IBC and IEBC typically do not apply to such buildings.

Existing Building Scenario 1: Normal Operations

​If you have an existing, permitted, occupied building that is proceeding with normal operations (meaning there is no construction activity occurring and you are not changing the use or occupancy of the building from the original design), “meeting code” is fairly simple.

​IBC/IEBC Compliance

First, the International Building Code (IBC) and International Existing Building Code (IEBC) generally do not apply to your building. The application of both codes is limited to situations where some level of work is occurring to the building.

For example, IBC 102.3.2 states:
The legal occupancy of any building existing on the date of adoption of this code shall be permitted to continue without change, except as otherwise specifically provided in this code, the International Fire Code or International Property Maintenance Code, or as is deemed necessary by the building official for the general safety and welfare of the occupants and the public.
In other words, the IBC does not require any change to your building unless there is a specific requirement in the International Fire Code (IFC), International Property Maintenance Code (IPMC), or the code official determines there is a required change necessary because of a threat to public safety. We’ll get to the IFC and IPMC shortly, but the final point is an important one to note. The code language does give the Building Code Official the authority to require a change to your building if they deem it is necessary for safety reasons.

In my experience, this authority is typically reserved for use when there is a clear danger to occupant safety. As a hypothetical example: if your building has an exit stairway that does not have any handrails, even though it was permitted that way from the beginning, the code official could deem the lack of handrails a big enough safety risk that they require you to install them. Assuming your building does not have any blatant safety risks, though, it’s unlikely that the code official would use this language to force a change in your building.

Similar to IBC Section 102.3.2, the IEBC has the exact same language in Section 101.4. Additionally, the overall scoping language in IEBC 101.2 states that the provisions of the IEBC apply to the “repair, alteration, change of occupancy, addition to and relocation of existing buildings.” So if you are not performing any of those actions on your building, the IEBC does not apply.

What about NFPA 101?

​​If you are in a jurisdiction that adopts NFPA 101, there are additional requirements you need to consider.
​
Unlike the ICC, which separates the IBC and IEBC into two different codes, NFPA 101 applies to both new and existing buildings. For example, NFPA 101 Section 7.1.1 states “Means of egress for both new and existing buildings shall comply with this chapter.” NFPA 101 Chapters 7-11 all apply to both new and existing buildings, so you’ll need to review these chapters for specific existing building requirements that could apply to your situation. After Chapter 11, NFPA 101 contains occupancy-specific chapters that only apply if those occupancies are in your building. These chapters alternate between new and existing occupancies (for example, Chapter 12 applies to new assembly occupancies and Chapter 13 applies to existing assembly occupancies). So the requirements found in any of the applicable “existing” chapters in NFPA 101 would also apply to your building.

IFC Compliance

​Second, certain portions of the IFC will apply to your building. The application of the IFC is divided into two categories:
  1. Construction and Design Provisions
  2. Administrative, Operational and Maintenance Provisions
Let’s cover these one at a time:

​IFC Construction and Design Requirements

Per IFC Section 102.1, the construction and design provisions of the IFC “apply to:
  1. Structures, facilities and conditions arising after the adoption of this code.
  2. Existing structures, facilities and conditions not legally in existence at the time of adoption of this code.
  3. Existing structures, facilities and conditions where required in Chapter 11.
  4. Existing structures, facilities and conditions that, in the opinion of the fire code official, constitute a distinct hazard to life or property.”

In our Scenario 1 case, Items 1 and 2 would not apply since we are an existing, permitted building.
Items 3 and 4 would apply, though. Item 3 sends us to IFC Chapter 11, and, Item 4, similar to the IBC, gives the code official authority to enforce the IFC on existing buildings if they deem there to be a distinct hazard to life or property.
IFC Chapter 11 primarily focuses on fire safety and means of egress requirements. A few examples include:
  • Standpipes in buildings with a floor higher than 50 feet
  • Smoke Alarms in Group R and I occupancies
  • Guards in the means of egress where the change in level is more than 30 inches
  • Handrails on at least one side of stairways

​These requirements are fairly basic and typically are not difficult to achieve, but this would be a good section to thumb through to determine if they apply to your building.  IFC Section 1103.1 details which sections of Chapter 11 apply based on the use and occupancy classifications in your building.

​IFC Administrative, Operational and Maintenance Provisions

​Per IFC Section 102.2, the administrative, operational and maintenance provisions of the IFC “apply to:
  1. Conditions and operations arising after the adoption of this code.
  2. Existing conditions and operations.”

​In our Scenario 1 case, both of these items apply. This means you’ll need to review the IFC chapters that are relevant to the given system or component of your building under consideration to determine if there are any applicable requirements. For example, if you are working with a dry-cleaning facility, there are requirements in IFC Chapter 21 that would apply to how you operate the facility and equipment.

​What about NFPA 1?

If you are in a jurisdiction that adopts NFPA 1 in lieu of the IFC, you’ll have a little more work to determine what applies to your building.
​
Similar to NFPA 101, NFPA 1 applies to both new and existing buildings and contains requirements for existing buildings throughout the code. You’ll need to review the chapters that are relevant to the given system or component of your building under consideration and then find the requirements for existing buildings located within those relevant chapters.

Existing Building Scenario 2: Changing an Existing Building

​If you are performing work on your building, there are additional code requirements beyond those described for Scenario 1.

​IEBC Compliance

The IEBC is your first stop for determining the applicable code requirements. IEBC Section 101.2 states that the provisions of the IEBC apply to the “repair, alteration, change of occupancy, addition to and relocation of existing buildings.” So you first want to review the definitions of each of these terms in IEBC Chapter 2 and determine which apply to the work you are performing in your building.

For repair work, the requirements of IEBC Chapter 4 apply. The general intent of this chapter is to maintain the existing level of code compliance in the building (at a minimum), though there are some specific additional requirements depending on the system or component undergoing repair.

For relocated building, the requirements of IEBC Chapter 14 apply.
​
For the other IEBC work classifications: alterations, changes of occupancy and additions, there are three potential compliance paths:
  • Prescriptive Compliance Method (IEBC Chapter 5)
  • Work Area Compliance Method (IEBC Chapters 6 through 12)
  • Performance Compliance Method (IEBC Chapter 13)

​Prescriptive Compliance Method

The prescriptive compliance method essentially requires the work being performed to comply with the requirements of the IBC, with a few exceptions involving situations where IBC compliance is unfeasible for an existing building.
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For many existing buildings, the requirements of the current edition of the IBC have progressed substantially since the building code that was in effect at the time of original construction, making any attempt to comply with the current IBC requirements difficult.

​Work Area Compliance Method

The work area compliance method is the most-commonly used compliance method in the IEBC and generally the most flexible from a technical requirement standpoint. This method applies varying requirements to the work area in the building based on the classification of work that is being performed. When the work area compliance method is used, the scope of work must comply with one or more of the applicable chapters:
  • Alterations – Level 1 (Chapter 7)
  • Alterations – Level 2 (Chapter 8)
  • Alterations – Level 3 (Chapter 9)
  • Change of Occupancy (Chapter 10)
  • Additions (Chapter 11)
  • Historic Buildings (Chapter 12)

For any building alteration, the requirements of Chapter 7 would apply. If the alteration includes “the addition or elimination of any door or window, the reconfiguration or extension of any system, or the installation of any additional equipment,” (IEBC Section 603.1), the requirements of Chapter 8 would also apply for a Level 2 alteration. If the work area exceeds 50% of the building, the requirements of Chapter 9 would also apply for Level 3 alteration.

Changes of occupancy and additions using the work area compliance method must comply with Chapters 10 and 11, respectively.
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Finally, if you have a historic building, be sure to reference IEBC Chapter 12 first, as it modifies several the requirements found in Chapters 7-11.

​Performance Compliance Method

The performance compliance method involves the evaluation of a variety of building systems and components (including height/area, compartmentation, vertical openings, means of egress, and fire protection systems). These systems are each assigned a score based on the evaluation criteria found in IEBC Chapter 13. These scores are then added to determine a total building score. If the score is high enough for the occupancy classifications involved, the work is deemed to be in compliance with the IEBC.
​
The performance compliance method is a good option when one aspect of a proposed scope of work cannot conform to the other compliance methods, but the remainder of the building is generally compliant. For example, if an existing building work areas has excessive dead corridor lengths, compliance with the prescriptive compliance method or work area compliance method may be impossible. But the performance compliance method may be a viable option, assuming the building scores well in the other assessment areas.

​IBC Compliance

As described above in Scenario 1, compliance with the requirements of the IBC is only required when specifically referenced by the IEBC (or potentially in the IFC and IPMC).
​
That said, if your work complies with the requirements of the current edition of the IBC adopted in your jurisdiction, this will inherently satisfy the requirements of the IEBC prescriptive compliance method.

​What about NFPA 101?

NFPA 101 Chapter 43 applies to any building rehabilitation work, including repairs, renovations, modifications, reconstruction, changes of use/occupancy and additions. Any of these actions would trigger a requirement to comply with NFPA 101 Chapter 43, which then brings in requirements to comply with other portions of NFPA 101, depending on the scope of work.
​
Generally, NFPA 101 Chapter 43 requires compliance with all requirements found in the applicable existing occupancy chapter (Chapters 13,15,17,19, etc.) plus some additional requirements that vary based on the type of work being performed.

​IFC Compliance

​As described in Scenario 1, application of the IFC is divided into two categories:
  1. Construction and Design Provisions
  2. Administrative, Operational and Maintenance Provisions
Let’s cover these one at a time:

​IFC Construction and Design Requirements

Per IFC Section 102.1, the construction and design provisions of the IFC “apply to:
  1. Structures, facilities and conditions arising after the adoption of this code.
  2. Existing structures, facilities and conditions not legally in existence at the time of adoption of this code.
  3. Existing structures, facilities and conditions where required in Chapter 11.
  4. Existing structures, facilities and conditions that, in the opinion of the fire code official, constitute a distinct hazard to life or property.”
​
Just as in Scenario 1, Items 3 and 4 would also apply to Scenario 2. Additionally, Item 1 would also apply to the work being performed in the building (since it is creating a new condition). Therefore, any requirement found in the IFC that is applicable to a system or component within the work being performed is applicable. This means you’ll need to review the IFC chapters that are relevant to the given system or component of your building under consideration to determine if there are any applicable requirements.

​IFC Administrative, Operational and Maintenance Provisions

​Per IFC Section 102.2, the administrative, operational and maintenance provisions of the IFC “apply to:
  1. Conditions and operations arising after the adoption of this code.
  2. Existing conditions and operations.”
Similar to our Scenario 1 case, both of these items apply to Scenario 2. 

​What about NFPA 1

There are requirements throughout NFPA 1 that would apply to Scenario 2, so again you’ll need review the chapters that are relevant to the given system or component of your building that will be changed and find the requirements for existing buildings within those chapters.

​Conclusion

The phrase “meeting code” is used frequently in the A/E/C world but depending on the nature of your building and the work being performed, it can mean many different things!
For an existing building, you likely fall under one of these two scenarios:
  • Scenario 1: Normal Operation of an Existing Building
  • Scenario 2: Changes to an Existing Building
​
Scenario 1 typically requires compliance only with certain portions of the IFC. Scenario 2 requires compliance with the IEBC and the IFC. If you are in a jurisdiction enforcing NFPA 1 and 101, there are also requirements from these codes that apply to both scenarios.
5 Comments

Three Approaches to Mixed Occupancy Buildings

2/18/2022

2 Comments

 
The IBC offers 3 approaches to mixed occupancy buildings: accessory, nonseparated and separated. Any building with two or more occupancy types must choose one or more of these approaches for compliance. In this post, we will cover all three of these approaches and the specific requirements related to each.
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Many urban buildings are mixed occupancy buildings and use one of these described approaches.

Nonseparated Mixed Occupancy

In a nonseparated occupancy approach, there is no requirement for a fire-rated separation between adjacent occupancies. However, the key requirement in a nonseparated occupancy approach is that the most restrictive requirements for the allowable height, area and number of stories, as well as the most restrictive fire protection requirements must be applied throughout the entire building. For example if your building has two occupancy types and one of them requires a voice fire alarm system, a nonseparated occupancy approach would mean that you need to provide a voice fire alarm system throughout the building.

If your building falls within the allowable height and area for the occupancy types involved and you can meet the fire protection requirements of the most restrictive occupancy, a nonseparated mixed occupancy approach is the easiest from a design standpoint because there is no additional requirements for rated separations.

    Check out the Nonseparated Mixed Occupancy Calculator

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The general approach for code compliance in a non separated mixed occupancy building is:
1. Determine the maximum allowable height, area and number of stories for each occupancy involved and verify that your building meets the most restrictive requirements.
2. Determine the fire protection requirements from IBC Chapter 9 for each occupancy involved and apply the most restrictive requirements throughout the building. If the building is a high-rise, the requiremetns of Section 403 would also apply throughout.
3. Apply all other code requirements, such as means of egress, to each individual occupancy classification individually for that portion of the building.

Note that even if you are taking a nonseparated occupancy approach there are specific requirements for buildings containing Groups H, I and R for a rated separation between those occupancies and adjacent building spaces you can review those requirements in IBC Chapter 4.

Separated Mixed Occupancy

The separated mixed occupancy approach is typically provided when the non-separated approach is not an option. With a separated mixed occupancy approach, a fire-rated separation is typically provided between each occupancy type. IBC Table 508.4 is referenced for the specific rating requirement, though a rated separation may not be required between occupancies of a similar hazard level.

The allowable height and number of stories is applied for each individual occupancy type. For example, if your construction type limits a Group A occupancy to 4 stories, your building could be taller as long as the Group A occupancy is not located above the fourth story.

The allowable area is based on the sum of the ratios of the actual floor area for each occupancy divided by the allowable floor area of that occupancy. The sum of these ratios cannot exceed one for any given story. Requirements for egress and fire protection systems are applied invidivualy to each separated occupancy in the building.

    Check out the Separated Mixed Occupancy Calculator

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The general approach for code compliance in a separated mixed occupancy building is:
  1. Determine the minimum required fire resistance rating between adjacent occupancies.
  2. Determine the actual area and allowable area for each occupancy involved.
  3. Verify that the sum of the actual to allowable area ratios is not more than 1 for any story and not more than 3 for the entire building (assuming an NFPA 13 sprinkler system).
  4. Verify that the locations of occupancies do not exceed their allowable height or number of stories based on the type of construction.
All other code requirements such as means of egress or fire protection are applied to each individual occupancy where it is located in the building. Note that Chapter 9 may require sprinkler protection throughout the building, even with separated occupancies, so be sure to review the requirements that apply to your specific situation.

Accessory Occupancy

The final option is an accessory occupancy approach. This method is applicable where there is a small portion of a building or space that is subsidiary to the main occupancy. When that smaller space is 10% or less of the total area of a story, an accessory occupancy approach can be used.

There is no required separation between the accessory and main occupancy, and the building height, area and number of stories are based on the main occupancy, not the accessory occupancy. If the building contains a Group H, I or R occupancy, those separation requirements found in Chapter 4 would still apply.

Within the accessory occupancy, other code requirements such as egress and fire protection systems are based on the accessory occupancy classification, not the main occupancy. This is crucial point that confuses many people. Essentially, the accessory occupancy designation allows you to ignore the height, area and number of stories requirements for the accessory occupancy, but all of the other code requirements for the accessory occupancy still apply.

For example, a large conference room located within an office building could be considered an accessory occupancy, so the limitations for height, area and number of stories for Group A-3 occupancies would not apply. But all of the other code requirements for Group A-3, including means of egress and fire protection requirements would still apply!

Bonus: Fire Walls

One final option - if you are able to separate multiple occupancies using a fire wall, you create two separate buildings from a code application standpoint and you can consider each building indvidually. A fire wall is the most robust separation option available though, so its likely to be the most disruptive from a design standpoint.

Conclusion

In summary, there are three approaches to mixed occupancy buildings: non separated, separated and accessory. All buildings with multiple occupancies must use one or more of these approaches. If your building contains three mor more occupancy types, it's possible to use a combination of the approaches, such as designating an accessory occupancy and then taking a nonseparated approach for the remaining occupancies.
2 Comments

Using Frontage to Increase Allowable Building Area

1/21/2022

7 Comments

 
If you have designed a building of Type II, III, IV or V construction, you probably considered the allowable building area, which depends on the construction type, occupancy classifications, presence of fire sprinkler systems, and a few other criteria.
​
One common way to increase the allowable area for a building is to use a frontage increase. The frontage increase provision in the IBC, found in Section 506.3, recognizes the safety benefits of having open space directly adjacent to a building. When a fire department or other emergency responders arrive to a site, there is an increased level of effectiveness when those personnel can access a large portion of the building exterior.
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A public way, such as a street that is at least 20 feet wide, counts towards the frontage increase.

​Using Frontage to Increase Allowable Building Area

There is no requirement for a building to use the frontage increase provisions of IBC Section 506.3, but when used, the following requirements apply:
  • A minimum of 25% of the building perimeter must be adjacent to a public way or open space
  • To count as frontage, the open space must be either on the same lot or a dedicated public space. Open space on an adjacent lot does not count.
  • The width of the open space must be at least 20 feet, measured at right angles from the building exterior wall to: (1) the closest interior lot line, (2) the entire width of the public way, or (3) the exterior face of a building on the same property.
  • The open space must be accessed from a street or fire lane

​Performing the Frontage Calculation

The frontage calculation can be performed by hand, but I recommend the building frontage calculator. If you want to do the calculation on your own, here are the steps. Note that this method is valid through the 2018 IBC. Starting in 2021, the method has changed, which I will cover in a future update.

1. Determine the weighted average of the width of open space (W). 

This value, W, is determined by the following equation:
W = (L1 x W1 + L2 x W2...)/F

Where:
Ln and Wn are the length of wall segment and width of open space adjacent to that wall segment. Remember that W has to be at least 20 feet. If the width of the public way or open space is greater than 30 feet, you are required to use a maximum value of 30 feet for the calculation.

F is total building perimeter fronting a public way or open space with a width of 20 feet or more.
2. Determine the total building perimeter, P.
3. Solve IBC Equation 5-5 to determine the frontage increase factor. 

If = [F/P - 0.25] W/30

​ The frontage increase factor can then be used with IBC Equations 5-2 or 5-3 to determine the allowable area the building. In these equations, the frontage increase factor is multipled by the "NS" allowable area value from IBC Chapter 5.

Notice that with Equation 5-5, the maximum possible frontage increase factor is 0.75. In order to achieve this maximum value, the entire building perimeter has to front an open space or public way with width of 30 feet or more. If the width at any point is less than 30 feet, or if a portion of the building perimeter does not have any frontage, the frontage increase factor will be reduced.

You can also directly input the frontage increase factor into the allowable area calculators below:
Link: Separated Mixed Occupancy Area Calculator
Link: Nonseparated Mixed Occupancy Area Calculator

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Conclusion

Using the frontage increase provisions of IBC 506.3 is a common way to increase the allowable area of a building. There is no requirement to use these provisions, but when you do, the requirement described above do apply.
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When working with architects, I frequently see code summary sheets with a frontage calculation for Type I buildings that have an unlimited allowable area. Since there is no requirement to take a frontage increase, I typically remind architects they don’t need to perform the frontage calculations if the building already has an unlimited allowable area. This saves time and also prevents possible permit review comments on a code provision that wasn’t needed in the first place.
7 Comments

NFPA 285: An Overview

1/7/2022

3 Comments

 
​NFPA 285 is the “Standard Fire Test Method for Evaluation of Fire Propagation Characteristics of Exterior Wall Assemblies Containing Combustible Components.” How’s that for a title? Despite the lengthy name, the goal of the test is quite simple – to understand how fire will spread on an exterior wall. In this article, we’ll briefly review the history of NFPA 285, discuss the criteria for the rest, and then review when compliance with NFPA 285 is required in the IBC.
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Many high-rise buildings require NFPA 285-compliant exterior wall assemblies.

NFPA 285 History

The NFPA 285 standard was first published in 1998 and is currently on it’s 4th edition, published in 2019. But the origins of NFPA 285 go all the way back to the 1970s, when foam plastic insulation became a popular choice for energy conservation in (or on) exterior walls. Based on work by the Society of Plastics Industry, the first test for flammability characteristics of an exterior wall was developed. This test was named UBC 17-6 and was first adopted by the Uniform Building Code (UBC) in 1988. This same test was later renamed as UBC 26-4 [1].

UBC 17-6/UBC 26-4 was a massive, full-scale test, consisting of a two-story exterior wall, totaling 24 feet in height (12 feet for each story). The test evaluated both vertical and lateral flame spread on nonload-bearing exterior walls containing foam plastics. Several wall assemblies containing foam plastics passed the test and, starting with the 1988 UBC, could be used as exterior wall assemblies in Type I, II, III and IV construction. A few years later, a modified test, using a smaller scale was adopted as UBC 26-9.
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10 years after the first adoption UBC 26-4, NFPA released the first edition of NFPA 285, entitled “Standard Fire Test Method for Evaluation of Fire Propagation Characteristics of Exterior Non-Load-Bearing Wall Assemblies Containing Combustible Components.” This version of NFPA 285, published in 1998, is the same as the UBC 26-9 test.
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Notice the difference in the name between the 1998 version of NFPA 285 and the 2019 version. The “nonload-bearing” restriction has been removed, now allowing load-bearing walls to be tested (although the standard itself does not require the application of a live load during testing).

NFPA 285 Test Criteria

The NFPA 285 testing criteria is nuanced, with variations based on the materials used in the wall assembly and the thickness of certain components in the wall assembly. For a full explanation of the acceptance criteria, review Section 10.2 of the 2019 edition of NFPA 285.

Generally, the acceptance criteria involves the following:

Flame propagation on the exterior face of the wall assembly
  1. ­Vertical flame spread of less than 10 feet above the window opening in the test
  2. Lateral flame spread of less than 5 feet from the centerline of the window opening
  3. Temperature less than 1000 F at a point 10 feet above the window opening

Flame propagation through combustible components and insulation

Depending on the materials used in the exterior wall assembly, there are various temperature requirements that must be met. These include:
  1. Limitations on temperature within exterior wall panels containing combustible components
  2. Limitations on temperature within the air cavity between exterior wall panels and the wall itself

These temperature requirements apply both vertically and laterally and are measured by thermocouples placed above and to the side of the first story window opening.

Temperatures in the second story

  1. The temperature in the second story room cannot rise more than 500 F above the temperature at the start of the test, measured 1-inch from the interior side of the wall assembly

Flame Propagation to second story

  1. Flames cannot spread to the inside of the second story room

Flame propagation to adjacent horizontal spaces

  1. Flames cannot spread horizontally beyond the side walls of the test

When is NFPA 285 Compliance Required?

In the 2021 IBC, there are a number of triggers for NFPA 285 compliance. If you are using an earlier version of the code, the requirements are fairly similar, but refer to the corresponding sections in the applicable code edition for the specific details.
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Water Resistive Barriers (IBC 1402.5)
Exterior walls in buildings of Type I, II, III or IV construction that are greater than 40 feet above grade plane must comply with NFPA 285 if they contain a water-resistive barrier. There are two key exceptions:
  1. If the water-resistive-barrier is the only combustible component in the exterior wall and the wall has a brick, concrete, stone, terra cotta, stucco or steel covering meeting the thickness requirements in IBC 1404.2.
  2. If the water-resistive-barrier is the only combustible component and it:
    1. Has a peak heat release of less than 150 kW per square meter, a total heat release of less than 20 MJ per square meter and an effective heat of combustion of less than 18MJ/kg when tested per ASTM E1354 with an incident heat flux of 50 kW per square meter.
    2. Has a flame spread index of 25 or less and a smoke-developed index of 450 or less as determined by ASTM E84.

For this section, fenestration products, flashing of fenestration and water-resistive-barrier flashing are not considered to be part of the weather-resistive-barrier. If any of these materials are combustible, the exceptions above do not apply.

Metal Composite Materials (MCMs) (IBC 1406.10.3)
Exterior walls containing MCMs in buildings of Type I, II, III or IV construction that are greater than 40 feet above grade plane must comply with NFPA 285. Note that the 2021 IBC has removed several exceptions that existed in previous editions regarding the height of the MCM panels and the area of wall covered by the panels.

High-Pressure Laminates (HPLs) (IBC 1408.10.4)
Exterior walls containing HPLs in buildings of Type I, II, III or IV construction must comply with NFPA 285. There are two key exception for when HPLs are installed 40 feet or less above grade plane:
  1. When the fire separation distance is 5 feet or less and the area of HPLs does not exceed 10% of the exterior wall surface area.
  2. When the fire separation distance is greater than 5 feet. In this case, the area of HPLs is not limited.

Mechanical Equipment Screens (IBC 1511.6.2)
Compliance with NFPA 285 is one of three possible code paths for providing combustible mechanical equipment screens on the roof decks of buildings of Type I, II, III or IV construction.

Foam Plastic Insulation (IBC 2603.5.5)
Exterior walls containing foam plastic insulation in buildings of Type I, II, III or IV construction of any height must comply with NFPA 285. There are several exceptions:
  1. One story buildings where the foam plastic has a flame spread index of 25 or less, smoke-developed index of not more than 450 and is covered by at least 0.032” of aluminum or 0.015” of corrosion-resistant steel and the building is fully sprinkler protected per NFPA 13. This exception only applies to foam plastic insulation with a thickness of 4” or less.
  2. When the foam plastic insulation is covered on each face by minimum 1” of masonry or concrete and one of the following conditions is met:
    • No airspace between the insulation and concrete/masonry cover.
    • The insulation has a flame spread index of 25 or less per ASTM E84 and the maximum airspace between the insulation and concrete/masonry cover is 1”.

​Fireblocking (IBC 718.2.6, Exception 3)
Fireblocking is not required in exterior walls when the exterior wall covering complies with NFPA 285.

    NFPA 285 Compliance Cheatsheet

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    Want an easy-to-read flowchart showing when NFPA 285 compliance is required? Enter your info below to download the cheatsheet.
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Key Items to Know

​Wall Assembly vs. Wall Components
NFPA 285 tests wall assemblies as a whole. Individual components of the wall are not considered, rather the entire exterior wall assembly is evaluated for compliance with the standard.

Deviation from NFPA 285 Assemblies
The use of Engineering Judgements (Ejs) for NFPA 285 compliance is a well-debated topic in the design industry. On one hand, it can be impractical to test an exterior wall assembly with every possible variation of material and component (remember that NFPA 285 is a full-scale test of a specific wall assembly). But on the other hand, it can be difficult to judge how variation from a tested assembly will impact performance.

While there are many exterior wall assemblies that have passed the NFPA 285 test, in my experience, many designers choose an assembly that has not been specifically tested. Many manufacturers of exterior wall products will obtain a testing report from ICC Engineering Services (an ICC ES Report, or something similar from another testing agency) that claims the product would pass NFPA 285 if tested. These reports, which essentially amount to a generalized EJ, are typically based on substituting one or more products into a wall assembly that has passed NFPA 285.

If the EJ route is chosen, the EJ should be provided by a qualified design professional, such as a licensed fire protection engineer with experience in the evaluation of exterior wall assemblies.

NFPA 285 vs. ASTM E119
NFPA 285 is different from ASTM E119, the test most commonly used to establish fire-resistance ratings for wall assemblies. This means that if your exterior wall is required to have a fire resistance rating, it also needs to have been tested per ASTM E119. Unfortunately, there are many walls that have a fire-resistance rating per ASTM E119 but do not pass NFPA 285. Similarly, there are walls that comply with NFPA 285 but may not be tested to ASTM E119.

This means that if your exterior wall is required to have a fire resistance rating and comply with NFPA 285, there are at least four potential code paths available:
  1. Provide an exterior wall assembly that has been tested to ASTM E119 for the required fire-resistance rating and has also passed NFPA 285
  2. Provide an exterior wall assembly that achieves the required fire-resistance rating using the prescriptive fire resistance method (IBC 721) or calculated fire resistance method (IBC 722) and has also passed NFPA 285.
  3. Provide a wall that uses an IBC ESR report (or similar) to achieve compliance with one or both of the testing requirements.
  4. Obtain an Engineering Judgement (EJ) to achieve compliance with one or both of the testing requirements.

Note that the acceptance of the last two items will vary by jurisdiction. In my experience, most AHJs are satisfied by an ICC ESR report, but the acceptance of EJs can vary greatly. See the section below for more on Ejs.

Finding NFPA 285 Wall Assemblies
To my knowledge, the best place to find wall assemblies that have been tested to NFPA 285 is the UL database. You can search “FWFO” in the UL directory to find the list, or checkout the database below of all UL-listed assemblies.

    Access the Database of all UL-Listed NFPA 285 Assemblies

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    Enter your info below for full access to the data of all UL-listed NFPA 285 assemblies.

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As mentioned earlier, many designers use the Engineering Judgement route to demonstrate NFPA 285 compliance. Wall assemblies using this code path are not listed in the above UL database.

Changes to the 2019 Edition
The 2019 edition has been updated with a new title, now allowing for load-bearing walls, but has also been updated with a few key technical changes. A few notable changes:
  1. Wood stud wall assemblies are now permitted in the test
  2. Protection of the window head, jamb and sill are now specifically described in the test (previously there was no requirement on how to detail these areas in the test)
  3. Joint locations – the new test now requires a vertical joint within 1 foot of the center of the window and a horizontal joint between 1 and 3 feet from the window.

​It’s crucial to note that the 2019 testing requirements are in many ways more rigorous than past editions. Wall assemblies that have passed earlier editions of NFPA 285 may not comply with the 2019 edition.
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Guide to Locking Egress Doors

11/11/2021

1 Comment

 
In 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 3 editions of the IBC.

Click one of the door/lock types in table below to jump to that section.
Component
2015 IBC
2018 IBC
2021 IBC
Revolving Doors
1010.1.4.1
1010.1.4.1
1010.3.1
Power-Operated Doors
1010.1.4.2
1010.1.4.2
1010.3.2
​Special Purpose Horizontal Sliding, Accordion or Folding Doors
1010.1.4.3
1010.1.4.3
1010.3.3
Educational Occupancies
-
1010.1.4.4
1010.2.8
Security Grilles
1010.1.4.4
1010.1.4.5
101.3.4
Group I-1 and I-2 Controlled Egress
1010.1.9.6
1010.1.9.7
1010.2.14
Delayed Egress
1010.1.9.7
1010.1.9.8
1010.2.13
Sensor Release of Electrically Locked Doors
1010.1.9.8
1010.1.9.9
1010.2.12
Electromagnetically Locked Doors
1010.1.9.9
-
-
Door Hardware Release of Electrically Locked Doors
-
1010.1.9.10
1010.2.11
Correctional Facilities
1010.1.9.10
1010.1.9.11
1010.2.15
Stairway Doors
1010.1.9.11
1010.1.9.12
1010.2.7
Panic and Fire Exit Hardware
1010.1.10
1010.1.10
1010.2.9
 

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.
Picture
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.
  1. Comply with BHMA A156.27 and the manufacturer's instructions.
  2. Each revolving door must have "breakout" capability per BHMA A156.27 and have an aggregate width of at least 36 inches.
  3. 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.
  4. 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).
  5. 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.
  6. 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.
  7. 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:
  1. Count towards no more than 50% or required egress width or capacity.
  2. Each door counts towards a maximum of 50 occupants when performing egress calculations.
  3. 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:
  1. Door power failure
  2. Sprinkler system activation
  3. Smoke detector activation with 75 feet of the revolving doors
  4. 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.
Picture
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:
  1. Group I-2 occupancies
  2. Special purpose horizontal sliding, accordion or folding doors (see related section in this article)
  3. 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.
Picture
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:
  1. The doors are power operated and are capable of being operated manually in the event of power failure.
  2. The doors are openable by a simple method from both sides without special knowledge or effort.
  3. 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.
  4. 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.
  5. 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.
  6. The door assembly must have an integrated standby power supply.
  7. The door assembly power supply must be electrically supervised.
  8. 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.
Picture
In Group E occupancies, Group B educational occupancies and (2021 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:
  1. 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.
  2. The door is openable from within the room per IBC 1010.2
  3. Modification are not permitted to listed panic hardware, fire door hardware or closers.
  4. (2021 only) Modifications to fire doors assemblies must be in accordance with NFPA 80.
 

​Security Grilles

Secutiry 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.
Picture
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:
  1. The door must unlock upon actuation of the sprinkler or smoke detection system.
  2. The door must unlock upon power loss.
  3. 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.
  4. No more than one controlled egress door before reaching an exit
  5. Door unlocking procures must be included and approved in the required Fire Code emergency planning (see IFC Chapter 4).
  6. All clinical staff must have a key or other means to operate the locked door
  7. Emergency lighting is required at the door.
  8. The door locking system must be UL 294 listed.
Exceptions: Items 1-4 above do not apply to the following situations:
  1. Areas where persons require restraint or containment as part of the function of a psychiatric treatment area or (2021 only) cognitive treatment area.
  2. 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.
Picture
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.
  1. Group B, F, I, M, R, S and U
  2. Group E classrooms with an occupant load less than 50
  3. 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:
  1. The delay electronics must allow immediate and free egress upon actuation of the sprinkler system or fire detection system.
  2. The delay electronics must allow immediate and free egress upon power loss.
  3. The delay electronics must have the capability to be deactivated from the fire command center or other approved location.
  4. 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.
  5. 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 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.
  6. 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.
  7. Emergency lighting must be provided on the egress side of the door.
  8. 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).
Picture
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:
  1. Sensor installed on egress side of door to detect an occupant approaching the door and cause the electric lock system to unlock.
  2. Door unlocks upon loss of power or signal to the sensor.
  3. Door unlocks upon loss of power to the lock or locking system.
  4. 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.
  5. Door unlocks upon activation of the building fire alarm system and remain unlocked until fire alarm system is reset.
  6. Door unlocks upon activation of the sprinkler system or fire detection system and remain unlocked until the fire alarm is reset.
  7. Door lock system must be UL 294 listed.
  8. (2021 Only) Emergency lighting must be provided on the egress side of the door.
 

​Electromagnetically Locked Doors

Picture
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:
  1. Hardware is affixed directly to the door leaf and has an obvious method of operation under all lighting conditions.
  2. Hardware can be operated with one hand.
  3. Operating the door hardware immediately interrupts power to the Mag Lock and unlocks the door immediately.
  4. Door unlocks upon lows of power to the locking system.
  5. Where panic or fire exit hardware is required, operation of that hardware also releases the Mag Lock.
  6. 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.
Picture
Door hardware release of electric locking systems on egress doors is permitted in all occupancies except Group H and requires compliances with the following:
  1. Hardware is affixed directly to the door leaf and has an obvious method of operation under all lighting conditions.
  2. Hardware can be operated with one hand and meets IBC unlatching requirements.
  3. Operating the door hardware immediately interrupts power to the lock and unlocks the door immediately.
  4. Door unlocks upon lows of power to the locking system.
  5. Where panic or fire exit hardware is required, operation of that hardware also releases the lock.
  6. Lock system must be UL 294 listed.
 

​Correctional Facilities

Picture
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:
  1. Activation of the building sprinkler system
  2. Actvaition of a manual fire alarm pull station
  3. 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

Picture
In some cases, stair doors can be locked from the inside, but never in the direction of egress.
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:
  1. Stair discharge doors can be locked from the outside (must be unlocked in direction leaving the stair).
  2. Stair doors in high rise buildings complying with IBC 403.5.3 (see section below).
  3. (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.
  4. (2018 and Beyond): 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.
  5. 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).
  6. 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

Panice 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. 
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The views, opinions, and information found on this site represent solely the author and do not represent the opinions of any other party, including the author's employer and the International Code Council, nor does the presented material assume responsibility for its use.  Local codes and amendments may vary from the code requirements described herein. Fire protection and life safety systems constitute a critical component of public health, safety and welfare and you should consult with a licensed professional for proper design and code compliance.
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