Code Change Proposal E112 - Exit Discharge onto Roof or Podium

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    ​

Link: Code Change Proposal 
Link: Hearing Recording 

Summary of Code Change 

• This proposal involves a new allowance in IBC 1028.2 to allow exit discharge onto the roof of a building or onto a horizontal building separation (podium) per IBC 510.2 when certain conditions are met: 
  • The exit discharge has a free and unobstructed path of travel that is readily visible and identifiable
    
  • The exit discharge does not include re-entering the building or utilizing an interior exit stairway/ramp or exterior exit stairway/ramp 
  • ​The structural bays of the roof assembly that support the exit discharge path contain no unprotected openings and have a fire-resistance rating not less than the exit enclosure that discharge onto the roof, or not less than one hour 

 
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.