Emergency Escape and Rescue Openings - Required in All Group R-2 Buildings?

I'm currently working on a large, multi-family apartment building that includes several-hundred dwelling units. The building is four stories tall and each story has multiple exits. The building is divided up by several fire walls for allowable area purposes, so the exits are a combination of exit stairs and horizontal exits.

​In a recent discussion, the AHJ indicated that he thought Emergency Escape and Rescue Openings complying with IBC 1030 were required for each bedroom in the building. On past projects, I have not seen this required in buildings where each story has two or more exits, so I decided to do a deep dive into the code requirements.

An emergency escape opening, in this case from a basement bedroom.

This project is under the 2015 IBC, but I have also included the 2018 language below, as this seems to further clarify the requirements.

2015 IBC 1030.1

In addition to the means of egress required by this chapter, provisions shall be made for emergency escape and rescue openings in Group R-2 occupancies in accordance with Tables 1006.3.2(1) and 1006.3.2(2) and Group R-3 occupancies. Basements and sleeping rooms below the fourth story above grade plane shall have at least one exterior emergency escape and rescue opening in accordance with this section. Where basements contain one or more sleeping rooms, emergency escape and rescue openings shall be required in each sleeping room, but shall not be required in adjoining areas of the basement. Such openings shall open directly into a public way or to a yard or court that opens to a public way.

2018 IBC 1030.1

In addition to the means of egress required by this chapter, emergency escape and rescue openings shall be provided in the following occupancies:

1. Group R-2 occupancies located in stories with only one exit or access to only one exit as permitted by Tables 1006.3.3(1) and 1006.3.3(2).
2. Group R-3 and R-4 occupancies.​

Basements and sleeping rooms below the fourth story above grade plane shall have not fewer than one exterior emergency escape and rescue opening in accordance with this section. Where basements contain one or more sleeping rooms, emergency escape and rescue openings shall be required in each sleeping room, but shall not be required in adjoining areas of the basement. Such openings shall open directly into a public way or to a yard or court that opens to a public way.

In the 2015 language, the first sentence seems to indicate that for a Group R-2 occupancies, the emergency escape requirements apply when triggered by Table 1006.3.2(1) or 1006.3.2(2). As I described in a recent cheat sheet for single exits, these tables are allowances for having a single exit or access to a single exit from a story. In this case, every story has multiple exits, so the provisions of these tables do not apply. The 2018 IBC makes this even clearer.

The AHJ on this project is pointing to the second sentence from the 2015 IBC 1030.1, stating that all sleeping rooms below the fourth story require the openings. The second paragraph from the 2018 IBC has similar language.

In my opinion, the first sentence of IBC 1030.1 essentially functions as scoping language for the rest of the requirements. Since this project does not meet the conditions described in this scoping sentence, the rest of the requirements do not apply and the openings are not required.

Emergency Escape and Rescue Openings: What Do You Think?

In a Group R-2 building where each story has multiple exits, are emergency escape and rescue openings required?

Let me know your thoughts in the comment box!