This post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH). Please note that I am serving on the 2024-2026 IBC Egress Committee, so many of these articles in this series will be egress related. Each post is my attempt to summarize the code change proposal and the presentation/discussion from CAH1, but please refer to the links below that include the actual code change proposal language and the CAH1 recording. These posts are not intended to provide my personal opinion or commentary on the code changes. Code Change Proposal E99 - Rating of Exit Passageway Link: Code Change Proposal Link: Hearing Recording Summary of Code Change This proposal seeks to clarify the required rating for an exit passageway. Essentially, the proposal states that exit passageways have a minimum rating of 1-hour, and then if they are extending from an interior exit stairway or ramp that they have to be not less than the rating of that stairway or ramp. Summary of Testimony and Discussion
The proponent of this proposal stated that the code intent has always been to allow a 1 hour exit passageway prior to entering a 2 hour exit stairway, but that the code has been frequently misinterpreted to require a 2 hour exit passageway any time there is a 2 hour exit stairway. There was minimal opposition testimony, with one participant stating they just need the proposal language to be clarified. CAH1 Result This code change proposal was approved by the committee, with a vote of 14-0.
2 Comments
For years, architect clients have asked me for a code solution to solve the challenge of corridors that exceed the dead end limit. As a quick reference, dead ends are limited to 20 feet, except in Groups B, E, F, I-1, M, R-1, R-2, R-4, S and U with a full NFPA 13 sprinkler system, where the limit is increased to 50 feet (2021 IBC 1020.5).
This post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH). Please note that I am serving on the 2024-2026 IBC Egress Committee, so many of these articles in this series will be egress related. Each post is my attempt to summarize the code change proposal and the presentation/discussion from CAH1, but please refer to the links below that include the actual code change proposal language and the CAH1 recording. These posts are not intended to provide my personal opinion or commentary on the code changes. Code Change Proposal E109 - Remoteness of Exit DischargeLink: Code Change Proposal
Link: Hearing Recording Summary of Code Change This proposal involves taking the existing exit remoteness requirements for exit and exit access doorways (typically one-half or one-third of the diagonal of the area served) and adding those requirements to the exit discharge. The proposal would prevent exit discharge doors from being located close to each other. Summary of Testimony and Discussion The proponent of this proposal testified that exit discharge points located too close together could result in a situation where a single fire event blocked the discharge of both exits in a two-exit building, resulting in an unsafe situation. Several participants testified in opposition of this proposal, noting that they believed it was overly restrictive and that the exit discharge was an inherently safer location that should not require such separation. A participant also noted that this would be extremely difficult to measure and arrange in a building with many exits. CAH1 Result This code change proposal was disapproved by the committee, with a vote of 14-0. This post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH). Please note that I am serving on the 2024-2026 IBC Egress Committee, so many of these articles in this series will be egress related. Each post is my attempt to summarize the code change proposal and the presentation/discussion from CAH1, but please refer to the links below that include the actual code change proposal language and the CAH1 recording. These posts are not intended to provide my personal opinion or commentary on the code changes. Code Change Proposal E110 - Exit Discharge Through a Lobby Using Signage
Link: Code Change Proposal Link: Hearing Recording Summary of Code Change This proposal involves a three word modification to IBC 1028.2 Exception 1. The current code language for this section allows not more than 50% of exit stairways to discharge through areas on the level of exit discharge when a number of conditions are met. The key condition at play here is that "Discharge of interior exit stairways and ramps shall be provided with a free and unobstructed path of travel to an exterior exit door and such exit is readily visible and identifiable from the point of termination of the enclosure." The code change proposal seeks to add "by exit signage" after the "readily and identifiable" clause. Summary of Testimony and Discussion The testimony for this code change proposal involved a desired alignment with NFPA 101, which already allows exit discharge through a lobby using exit signage and does not explicitly require a clear line of site from the stairway to the exterior exit door. A point about distance limitations was brought up, but this code change proposal does not include any distance limits between the exit stair and the exterior exit door (it was noted by participant testimony that the overall exit travel distance requirement would still apply on the floor). This proposed change would no longer require a clear line of site between the stair door and door to the exterior, but will now require that the door to the exterior be readily visible and identifiable by exit signage. CAH1 Result This code change proposal was approved by the committee, with a vote of 13-0. This post is a continuation of the Proposed Code Change Series, where I highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH). Please note that I am serving on the 2024-2026 IBC Egress Committee, so many of the articles in this series will be egress-related. Each post is my attempt to summarize the code change proposal and the presentation/discussion from CAH1, but please refer to the links below that include the actual code change proposal language and the CAH1 recording. These posts are not intended to provide my personal opinion or commentary on the code changes. Code Change Proposal E112 - Exit Discharge onto Roof or Podium Summary of Code Change
Summary of Testimony and Discussion The proponent of this proposal testified that this code change addresses a common situation in building design, where a building exit discharge to a space that is outdoors but above the roof of the building (for example, a building that has below grade parking that extends beyond the footprint of the building above grade). The proponent noted that the proposal requires the roof assembly to have the same rating as the exit enclosure itself, thereby providing an equivalent level of protection. One participant testified in opposition of this proposal, noting that they believed the roof of a building could not be considered exit discharge and that this proposal needed to be relocated to a different portion of the code. The committee had a number of back and forth comments on this proposal. One committee member felt that this approach should not be directly allowed by the code but should be handled on a case-by-case basis through a code modification or variance process. I commented during the hearing that I have seen this approach taken on multiple buildings and voted in support of the proposal. I also noted that when this approach is used on an IBC 510.2 podium building, occupants would have atleast a 3 hour rated horizontal assembly beneath them and would be open to the sky, resulting in a fairly high level of protection. CAH1 Result This code change proposal was approved by the committee, with a vote of 8-6. Welcome to a new blog series, where over the next couple of months, I will highlight some of the interesting and controversial code changes that were presented at the 2024 ICC Committee Action Hearings (CAH). These proposed changes, which could become part of the 2027 ICC codes, are the first step of the updated ICC code development process that now includes two Committee Action Hearings (CAH1 and CAH2), as well as the Public Comment Hearing (PCH). Please note that I am serving on the 2024-2026 IBC Egress Committee, so many of the articles in this series will be egress related. Each post is my attempt to summarize the code change proposal and the presentation/discussion from CAH1, but please refer to the links below that include the actual code change proposal language and the CAH1 recording. These posts are not intended to provide my personal opinion or commentary on the code changes. Code Change Proposal E24 - Single Exit R-2 Buildings up to Six Stories Summary of Code Change This proposal involves a modification to IBC Section 1006 to allow a single exit in Group R-2 buildings up to six stories when several conditions are met, including:
Summary of Testimony and Discussion The testimony for this code change proposal was intense! Dozens of people appeared to testify and the overall time spent, including testimony and committee action was over an hour. The proponent of this proposal seemed to be motivated primarily by a need for affordable housing, claiming that the requirement for a second exit stairway in certain residential buildings drives costs and makes development of some residential buildings infeasible. The opposition testimony to the proposal included a wide variety of perspectives. Many participants cited the life safety risk for both building occupants and first responders. Others stated that such a code change was inappropriate at the national level and should be left to state and local jurisdictions to amend the code as needed. Several participants brought up the cost to install and maintain a smokeproof enclosure for the stairway, as well as the added cost of providing standby power for such systems. CAH1 Result
After extensive testimony and discussion, this code change proposal was disapproved by the committee, with a vote of 14-0. Note that a similar code change proposal, E25, was also submitted, to allow the same single exit arrangement in Group R-1 occupancies. This code change proposal was also disapproved by the committee, with a vote of 14-0. Key Takeaway: Winder stairs are generally limited to dwelling units or very small spaces, unless the stair can meet the more restrictive requirements for curved stairways. Winder stairs, or specifically, winder treads, are a unique architectural feature that an architect or engineer can use when designing a stairway. The International Building Code (IBC) has several limitations on the use of winder treads through, restricting the situations where they can be used. In this post, we are going to explore the code requirements for winder treads to determine how they need to be designed and where they can be used. All references are to the 2021 IBC. If you are working on a one or two family dwelling, a separate set of requirements from the International Residential Code (IRC) likely applies. 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.
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). 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. 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? |
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September 2024
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