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.

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

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

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.

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 are common in accessible 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.

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 doors, such as horizontal sliding doors, are found in airports, malls, grocery stories and many other building types.  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.

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

In Group E occupancies, Group B educational occupancies and (2021 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.

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.

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 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.

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

Where permitted:

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

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

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.

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).

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 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.

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

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

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 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.

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.

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. 

In the A/E world, there is much confusion regarding the definition of fire protection rating and fire resistance rating when designing doors, windows, transoms, sidelights and other openings in rated construction. These terms are often used interchangeably by mistake, but they represent two very different types of assemblies. A third term, "fire rating", is often used as well, making the distinction even more confusing. In this article, we'll review the differences between fire resistance ratings and fire protection ratings and show you how to determine the requirements for your specific situation. All code references are to the 2018 IBC.

Before distinguishing between fire-resistance-rated assemblies and fire-protection-rated assemblies, it's important to note that both of these are types of fire-rated assemblies. So if someone refers to a fire-rated glazing assembly, they could be potentially referring to either a fire-resistance-rated assembly or a fire-protection-rated assembly. The majority of the requirements for either type of assembly come from IBC Table 716.1(2).

Fire-resistance-rated assemblies are those that have been tested to ASTM E119 or UL 263. This is the same test that is used for rated wall, floor and ceiling assemblies. Therefore, if you have a door, window, shutter or any other type of openings protective that is tested to ASTM E119 or UL 263, it is treated no differently than a rated wall or floor. There are no limitations to the area or location where you can provide such opening protectives. 

Functionally, these tests measure an opening protective's ability to stop the transmission of smoke/flames AND to limit the transmission of radiant heat. In order to pass ASTM E119 or UL 263, assemblies must limit the temperature rise on the non-fire side of wall/floor to 250 degrees or less.

Any fire-rated glazing assembly, whether a fire-resistance-rated assembly or fire-protection-rated assembly, is required to be labelled per IBC 716.1.2.2.  The markings for these assemblies are shown in IBC Table 716.1(1) and replicated in the table provided below. For fire-resistance-rated glazing, you are looking for markings containing either a "W" or "F". If the marking does not contain either of these letters, the assembly is not fire-resistance-rated. Fire doors are required to be labelled per the requirements of NFPA 80.​

Fire Doors
In interior fire doors that require a 1-hour rating or greater, fire-protection-rated glazing is permitted in the door vision panel up to 100 square inches. The glazing in the door vision panel is required to pass the hose stream test and bear the "D" and "H" markings. The duration (in hours) of the required rating depends on the type and rating of the wall itself - specific requirements are provided in IBC Table 716.1(2). If a vision panel greater than 100 square inches in area is desired, the vision panel must be fire-resistance-rated glazing and bear the "W" marking. Additionally, vision panels exceeding this area in exit stairways, ramps and passageways must meet the maximum temperature rise criteria of 450 degrees after 30 minutes and bear the "T" marking. There is an exception for this temperature rise criteria if the building is fully-sprinkler protected in accordance with NFPA 13 or 13R. Finally, sidelights and transoms adjacent to fire doors that require a 1 hour rating or greater are required to have a fire-resistance-rating equal to that of the wall itself; fire-protection-rated glazing is not permitted in these.

If the fire door requires a 45 minute rating or less, fire-protection-rated glazing is permitted in the door vision panel up to the maximum size tested. There is no requirement for fire-resistance-rated glazing in such doors. Sidelights and transoms adjacent to these doors are required to have a fire protection rating of either 20 or 45 minutes depending on the location. Refer to IBC Table 716.1(2) for the specific requirements.

Fire doors in rated exterior walls have slightly different requirements. If the exterior wall has a rating greater than 2 hours, the fire door is required to have at least a 90-minute rating and a fire-protection-rated vision panel is permitted up to 100 square inches in area. Any sidelights and transoms are required to have a fire-resistance-rating the same as the wall itself.

Exterior walls rated 2 hours or less are permitted to have fire-protection-rated glazing in the door vision panel, sidelight and transom. The rating requirement for these elements is the same as the door itself.

Fire Windows
Fire-protection-rated glazing is permitted in certain fire windows in interior wall assemblies, up to a maximum rating of 45 minutes. Fire windows in fire walls and fire barriers (excluding atrium separation, incidental use separations and occupancy separations) are required to have fire-resistance rated glazing. Refer to the table below, based on requirements form IBC Table 716.1(3). Note that walls allowing fire-protection-rated glazing can be provided with fire-resistance-rated glazing as indicated, but this is not required.

*except those noted in the next row
​
Fire-protection-rated glazing is permitted in all fire windows in exterior walls, as described in the table below. IBC Table 705.8 provides requirements for opening protectives in exterior walls, so be sure to refer there as well. Depending on the fire separation distance, you may be permitted to have unprotected openings in a rated exterior walls. Conversely, if the fire separation distance is less than 3 feet, you are not permitted to have any openings in the exterior wall, even if they have a fire protection rating. Fire-resistance-rated glazing is always permitted since it must meet the same test criteria as the wall itself.

There are two types of fire-rated openings protectives: fire-resistance-rated and fire-protection-rated assemblies. Fire-resistance-rated assemblies have to meet the same test criteria, ASTM E119 or UL 263, as a rated wall or floor assembly. Since the test is the same, there are no size or location limits for where you can provide fire-resistance-rated protectives. Fire-protection-rated assemblies are tested to lesser criteria and are limited in size and location. Full requirements for both types of assemblies are found in IBC Table 716.1(2).

If you have been involved in the design or installation of a fire alarm system, whether as an architect, engineer, or owner, you have probably asked the question, "Is a strobe required here?" Like all engineering questions, the answer depends on a number of factors. In this post, I will walk through the code path step-by-step to help you understand where fire alarm strobes are required.

The starting point for determining strobes requirements is the applicable building code for your jurisdiction. If you are in the United States, this is most likely based on the International Building Code (IBC). For projects located elsewhere, this could be NFPA 5000. Buildings owned or operated by the government could also be subject to other requirements, such as the GSA PBS-P100 or UFC 3-600-01. You may also be in a jurisdiction that enforces NFPA 101, which also has requirements for fire alarm systems.

Assuming the applicable code is the IBC (all references here are to the 2018 IBC), your first step is to check Section 907.2 to determine if a fire alarm system is required for your building. This section requires a fire alarm system based on occupancy type and other building criteria, such as classification as a high-rise building. In some instances, 907.2 requires a manual fire alarm system (pull stations) and in others a smoke detection system. For the purposes of this article though, the main concern is whether any type of fire alarm system is required at all. That's because, according to IBC 907.2, if a fire alarm system is required by Sections 907.2.1 through 907.2.23, occupant notification is required.

Fire alarm equipment required outside of Section 907.2 such as duct smoke detectors or elevator emergency operations would not trigger a requirement for strobes.

In addition to the occupancy requirements above, IBC 907 provides requirements for specific building situations.

Once you have determined that a fire alarm system is required, you'll want to flip ahead a few pages to determine which rooms require strobes. The starting point is IBC 907.5.2.3:

Public Uses Areas and Common Use Areas
Strobes are required in public and common use areas, with the exception of employee work areas, which are permitted to be provided with spare circuit capacity to account for future addition of strobes if needed for hearing-impaired employees. Public use and common use are defined terms in the IBC:

Common Use: Interior or exterior circulation paths, rooms, spaces or elements that are not for public use and are made available for the shared use of two or more people.

Public Use Areas:  Interior or exterior rooms or spaces that are made available to the general public.

Examples of spaces that fall under one of these categories are: lobbies, corridors, circulation areas, meeting rooms, conference rooms, assembly areas, public or shared restrooms, retail spaces, and classroom. This is by no means an exhaustive list, so you'll need to consider each space in your building to verify if it falls under the definition of public use or common use.

Groups I-1 and R-1
Strobes are required in a certain percentage of dwelling and sleeping units in Group I-1 and R-2 occupancies. Refer to the table below, replicated from IBC Table 907.5.2.3.2.

Group R-2
Group R-2 occupancies requiring a fire alarm system must have the capability to support strobes appliances in the future. The intent is that the fire alarm system has the capability to be modified if a hearing impaired occupant were to  move into the sleeping or dwelling unit.

The final step is to review other documents that could drive strobe requirements. One common question is whether or not ADA Accessibility Guidelines (ADAAG) or NFPA 72 require strobes in certain rooms. Neither of these documents actually require a fire alarm system or strobes to be installed at all. When a fire alarm system is provided, however, ADAAG brings in requirements for where visible notification is required. Similarly, NFPA is only applicable when the IBC or other applicable codes require a fire alarm system.

Assuming you are required to provide a fire alarm system, the requirements of NFPA 72 would apply (ADAAG would also apply, assuming your building is required to comply with the Americans with Disabilities Act (ADA), which is a longer discussion for another article). In most cases, if you provide a fire alarm system and a strobe layout that complies with the IBC and NFPA 72, you will meet the requirements of ADAAG.

The general process for determine strobe requirements is:

1. Determine if a fire alarm system is required for your occupancy and/or specific building situation in the applicable codes.
2. If a fire alarm system is required, determine if visible notification (strobes) are required. The most common drivers are:
   1. Public use and common use areas
   2. Group I-1 and R-1 sleeping/dwelling units
3. Check other requirements. These could be additional local codes/standards, particularly amendments or additional requirements to NFPA 72 or ADAAG.

New on the blog today is an occupant load calculator based on factors from the 2015, 2018 and 2021 editions of the IBC. Check it out at the link below!

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."

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)

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!

If you disagree with this viewpoint, there is still time to have your opinion heard before the change is codified. The ICC code development process includes a public comment period, which will be open between May 24 and July 2. Any one is free to submit a comment on this issue or any other proposed changes moved forward by ICC committees. The ICC Public Comment Hearings (PCH) will take place between September 22-29 in Pittsburgh (also open to the public).

The 2021 IBC includes several changes that impact Group I-2 occupancies. These changes build upon updates from 2018 edition and continue with the sub-grouping of occupancies into either Condition 1 or 2 that started in the 2015 edition. As a quick reminder, IBC 308.3 defines these as:

Group I-2, Condition 1: "facilities that provide nursing and medical care but do not provide emergency care, surgery, obstetrics or in-patient stabilization units for psychiatric or detoxification, including but not limited to nursing homes and foster care facilities."

Group I-2, Condition 2: "facilities that provide nursing and medical care and could provide emergency care, surgery, obstetrics or in-patient stabilization units for psychiatric or detoxification, including but not limited to hospitals."

The 2021 IBC provides two changes related to corridors doors in Group I-2 occupancies.

First, Section 407.3.1.1 has been added for corridor doors that are not required to have a fire protection rating. Generally, Group I-2 corridor walls are not required to have a fire-resistance rating unless they are part of an enclosure for an exit or vertical opening, or if they are separating an incidental use room that requires a rating per IBC 509.4.

This new section now addresses the following:

• Solid doors, which are now specifically required to have close fitting operational tolerances, head and jamb stops
• Dutch-style doors, which are now specifically allow, but must have the following features:
  • An astragal, rabbit or bevel at the meeting edge of the upper and lower sections
  • Latching hardware on both the upper and lower sections
  • Hardware that connects the upper and lower sections, allowing them to function as a single leaf
• Makeup air: when used to provide makeup air for exhaust systems (per Section 1020.6 Exception 1), doors are now specifically permitted to have either louvers OR up a 2/3" bottom gap

​Second, Section 407.6.1 has been added for automatic-closing doors on hold-opens. Previously, these doors were only required to close upon actuation of a smoke detector or loss of power to the hold-open or smoke detector. Now, these doors must also close upon activation of the fire alarm system or sprinkler system.

Section 407.4.4.3 has been revised and no longer considers the number of doors or care suites in the path of exit access. Previously, this code section limited exit access to not require passage through more than three doors before reaching the corridor. Now, the code does not provide a maximum number of doors and simply limits care suites to no more than 100' of travel to reach a corridor. When a care suite requires two exit access doors, the second exit access door must lead directly to a corridor, exit or adjacent care suite.

The 2021 IBC makes an organizational change to requirements for nursing home cooking facilities, moving the requirements for the cooking appliances into a separate section. This builds upon a change in the 2018 edition, which provided specific provisions to allow cooking facilities to be open to the corridor in Group I-2, Condition 1 occupancies.

Under the 2021 IBC, these requirements are now organized as follows:

Nursing Home Cooking Facilities (407.2.6): In Group I-2, Condition 1 occupancies, spaces containing a cooking facility with a domestic cooking appliance are permitted to be open to the corridor when all of the following criteria are met:

• No more than 30 care recipients in the smoke compartment containing the cooking facility (or served by the facility)
• No more than one cooking facility per smoke compartment
• A clearly delineated corridor space is provided
• The cooking facility can not obstruct access to the exit
• The cooking appliance must comply with 407.2.7

Domestic Cooking Appliances (407.2.7): In Group I-2 occupancies, cooking appliances in domestic cooking facilities must comply with the following:

• Appliances limited to ovens, cooktops, ranges, warmers and microwaves
• Domestic cooking hood installed in accordance with IMC 505 provided over cooktops and ranges
• Cooktops and ranges protected with Section 904.14.1, which requires either a fire extinguishing system in the hood OR a burner that is listed to prevent ignition of cooking oils. While the code does not give a specific standard for the listing, any appliances listed to the new Section 60A in UL 858 would meet this criteria. In the US, electric burners sold after April 2019 are required to meet this criteria.
  • This requirement does not apply for cooktops and ranges used for care recipient training or nutritional counseling purposes
• A fuel/electrical power shutoff for the cooking equipment is provided in a staff-only area
• A timer is provided that automatically deactivates the equipment in 120 minutes or less
• A fire extinguisher is provided within 30 feet of each domestic cooking appliance

The 2021 IBC includes several changes related to Group I-2 occupancies. These changes build upon provisions enacted during past cycles and include changes to corridor doors, care suite arrangement and nursing home cooking facility requirements.

As more and more states move to adopt the 2018 IBC, it's important to know about a few code updates that impact the design of occupied roof spaces. And if you're jurisdiction is on the ball and already adopted the 2021 IBC, there are a few additional items that apply to you.

In the 2015 IBC and prior editions, the code remained silent in regards to occupied roof decks and requirements for allowable height and area.  Under the 2018 IBC, there are now specific provisions addressing this issue.

First, IBC 302.1 has been updated with specific requirements for classifying an occupied roof space:

This section limits the occupancy on an occupied roof to those allowed on the story immediately below the roof. So if your building construction type allows an assembly occupancy on the top story, you are also permitted an assembly occupancy on the roof. The code does offer two major exceptions:

1. If your building if fully sprinkler-protected (NFPA or 13R) and you have fire alarm notification on the occupied roof, you are permitted to have any occupancy on the occupied roof.
2. If your building is Type I or II construction, you are permitted to have assembly occupancies on the roof of parking garages.

Take the image below for an example, a 4 story building consisting of Type IIIA construction. If the building is fully sprinkler protected in accordance with NFPA 13, a Group A-3 occupancy would per permitted on Level 4. As long as occupant notification is provided on the roof, the 2018 IBC now explicitly allows a Group A-3 occupancy on the roof.

The 2021 IBC updates Section 503.1.4 to explicitly clarify that an occupied roof should not be included when determining building height or number of stories per IBC 504. Language was also added to clarify that this only applies when penthouse and other rooftop structures, when present, comply with IBC 1511. This further supports the notion described above that an occupied roof should not by itself trigger a classification as a high-rise building.

Additionally, the 2021 IBC clarifies that the Exception 1 to 503.1.4 for occupant notification would only require a voice fire alarm system on the roof if the system is required elsewhere in the building. In other words, if you aren't required to have a voice fire alarm in the building, you don't have to provide it on the roof in order to use Exception 1.

Finally, the 2021 IBC updates Section 1511.2.2, Use Limitations for Penthouses, to specifically allow "ancillary spaces used to access elevators and stairways" to be considered part of a penthouse. This means that a stair or elevator tower to the roof will not force an occupied roof to be classified as a story, even though those elements are taller than 48" from the roof surface.