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The Building Code Blog

Code Change Proposal E110 - Exit Discharge Through a Lobby Using Signage

7/9/2024

4 Comments

 
​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.
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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. 

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4 Comments
Greg Overkamp
7/9/2024 11:48:05 am

This is a welcome change and in better alignment across the codes.

Reply
William Sullivan
7/9/2024 12:58:31 pm

I would like to disagree that this is a welcome change, to dump an exit stair into the first floor and still allow them to navigate 150-200 ft of travel in a potentially smoky environment does not seem to make sense to me. Yes, I have seen a number of architectures propose this saying the hallway is part of the lobby because there are no doors, headers.

Reply
Roger W Fast
11/26/2024 02:52:59 pm

William, I couldn't agree more.

Greg Franzen
7/17/2024 10:53:45 am

Thanks for the blog - it is a helpful info share.

I think this is an appropriate change, but I don't agree with how the proponents portray the meaning. The new text allows the exterior exit door to be identified because it has an exit sign (vs eg being identified because it is a glass door and the occupant can see the exterior). However, this visibility and identification of "the exterior exit door" must still occur "from the point of termination of the enclosure" under the new text, same as the old.

Also note that the travel distance limitations of Section 1017 only apply to the "exit access" - ie per the definitions, the measurement stops once the "exit" (stair enclosure) is reached. Under Section 1028, the occupant has reached the "exit discharge" so that distance limitation does not apply. So the proponents would indicate that the exit discharge could be thru any maze of hallways of any length, provided there are exit signs to guide the path. Keeping in mind that the base requirement of Section 1028 is that the "exit discharge" be directly to the exterior, it is reasonable that the exception intends only something that is direct and obvious as soon as the occupant leaves the protection of the "exit" enclosure.

The proponent's written statement on the change proposal indicates that being able to see the exterior door from the stair termination is a "common misconception" - that is not correct. It is the actual text of the code, and clearly supported by the IBC Commentary.


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  • Home
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  • Tools
    • Allowable Height & Area Calculator - Non-Separated Mixed Occupancy
    • Allowable Height & Area Calculator - Separated Mixed Occupancy
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    • Fire and Smoke Damper Tool
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