August Update + A Means of Egress Question

It's been a full summer here on my end, at least in one sense. While the pandemic has forced vacation cancellations and generally fewer social gatherings, work has been full steam ahead for the past few months. I've also been working on a weekly basis to help PE Roadmap clients as they study for the Fire Protection PE exam this fall. As we get towards the last remaining months before the October exam, I am looking forward to some more regular posts on the blog, which I anticipate to be a mixture of life safety tools, cheat sheets and code questions.

On another front, I've also had some recent conversations with Joe Meyer over at MeyerFire regarding our Code Calls initiative. While we are still soliciting feedback from Indiana AHJs regarding their local requirements, we are also looking for some ways to further jump start our progress. One of these is putting together a database that provides a link to State/City/County/Municipality local amendments, as well as the link to that jurisdiction's website where you can find contact information. Similar to the main Code Calls database, we are starting in Indiana and hoping to branch out from there. More on that in the coming months.

Code Question - Openings in Stairs From Normally Occupied Spaces

On a recent project, an architect I am working with received a comment stating that openings in stairways are only permitted from normally occupied spaces. I have come across this requirement before, which originates from IBC 1023.4.

​Openings in interior exit stairways and ramps other than unprotected exterior openings shall be limited to those necessary for exit access to the enclosure from normally occupied spaces and for egress from the enclosure. (2015 IBC 1023.4)

While I am quite familiar with this requirement, the fact that it was brought up in this particular situation was shocking. That's because the floor in question, a basement, was designed with two exit stairs and an enclosed corridor running the length of the building and connecting the stairs. I've sketched up a simplified version of the layout below. The plan review comments indicated that the openings into the stairs were from not-normally occupied spaces and did not comply with IBC 1023.4.

Sketch of the proposed basement layout with a corridor connecting the two exit stairs.

If either of the stairs opened up directly into the mechanical, electrical or storage rooms, this comment would make sense to me. However, the openings into both stairs are from the corridor, which I have always considered normally occupied space. In fact, the IBC actually requires rated corridors to continue to an exit (IBC 1020.6). While the corridors in this design are not currently rated, if the code requires corridors continuity to an exit in certain situations, how could a corridor be considered not-normally occupied here?

Upon a followup conversation with the plan reviewer, the local jurisdiction has taken the position that because all of the rooms (mechanical, electrical and storage) on the floor are considered not-normally occupied, the corridor serving those rooms should be treated the same. The reviewer also cited concern that corridor could be used for storage and result in potential fire spread into the stair.

When I brought up potential solutions, it seems that rating the corridor (or providing a rated stair vestibule) would satisfy the jurisdictions concerns.

What Do You Think?

I would love to hear your thoughts on this situation. Should this corridor be considered not normally occupied? Does this design meet the intent of IBC 1023.4? Let me know in the comments section!