Maneuvering clearance

[Sifu]

2021 IBC, 20017 ANSI 117.1: Given a door to an interior exit stair from a story. The stair is not an accessible means of egress. Is a maneuvering clearance required from inside the stair back onto the floor?

Same question if it is an accessible means of egress.

 

[RLGA]

I have been told that, yes, clearances are required on the stair (i.e., landing) side of a stairway door. Although wheelchair users will likely not use the stairs for obvious reasons, there may be situations where stairs are used by an occupant with a cane or some other physical disability that may not affect their ability to use the stairs but may have difficulty opening the door.

 

[redeyedfly]

2021 IBC, 20017 ANSI 117.1: Given a door to an interior exit stair from a story. The stair is not an accessible means of egress. Is a maneuvering clearance required from inside the stair back onto the floor?

Same question if it is an accessible means of egress.

Yes. Door maneuvering clearances are not solely for people in wheelchairs. Many people have physical disabilities that allow them to use stairs but need additional space at doors. Limited mobility in an arm is one example.

You might want to open your code book again regarding AMOE.

 

[Yankee Chronicler]

I'm going to have to disagree with RLGA. A117.1 calls for accessible routes "required by the scoping provisions adopted by the administrative authority" ( i.e. the building code) to comply with the technical provisions.



Stairs are not considered to be part of an accessible route. Yes, persons with certain mobility impairments but not in a wheelchair may be able to use stairs, and the nosing and handrail requirements are intended to facilitate this, but the core of the issue is that stairs are not part of a required accessible route. Since stairs are not part of an accessible route, door maneuvering clearances do not apply.

The exception, of course, would be a stairway in which the landing(s) serve(s) as an area of rescue assistance.

 

[Sifu]

My thinking is that even if a stair is not an accessible route, or an accessible means of egress, IF a user went in, realized they could not traverse the stair, they would need to return back to the floor. In a sprinklered building most stairs can be considered an accessible means of egress.....EGRESS, 1009.2 does indeed include interior exit stairs as a means of egress but no mention of access back onto the floor. I do occasionally open the code book.

This stair is in a 3 story building requiring two MOE's and two AMOE's. The elevator serves as one accessible MOE, one or both of the stairs would be the other (no area of refuge required in a sprinklered building). If for whatever reason the stair is not viable, there is no maneuvering clearance back onto the floor. Yankee gets to the question...once in the stair, is an accessible route back required? Seems like this has been discussed before, but I can't recall the high points.

 

[redeyedfly]

I'm going to have to disagree with RLGA. A117.1 calls for accessible routes "required by the scoping provisions adopted by the administrative authority" ( i.e. the building code) to comply with the technical provisions.

View attachment 14594

Stairs are not considered to be part of an accessible route. Yes, persons with certain mobility impairments but not in a wheelchair may be able to use stairs, and the nosing and handrail requirements are intended to facilitate this, but the core of the issue is that stairs are not part of a required accessible route. Since stairs are not part of an accessible route, door maneuvering clearances do not apply.

The exception, of course, would be a stairway in which the landing(s) serve(s) as an area of rescue assistance.

Show me where the stair landings are exempted from being on an accessible route.

 

[redeyedfly]

My thinking is that even if a stair is not an accessible route, or an accessible means of egress, IF a user went in, realized they could not traverse the stair, they would need to return back to the floor. In a sprinklered building most stairs can be considered an accessible means of egress.....EGRESS, 1009.2 does indeed include interior exit stairs as a means of egress but no mention of access back onto the floor. I do occasionally open the code book.

This stair is in a 3 story building requiring two MOE's and two AMOE's. The elevator serves as one accessible MOE, one or both of the stairs would be the other (no area of refuge required in a sprinklered building). If for whatever reason the stair is not viable, there is no maneuvering clearance back onto the floor. Yankee gets to the question...once in the stair, is an accessible route back required? Seems like this has been discussed before, but I can't recall the high points.

Can you lock the stair door from inside the shaft to the corridor? No, not unless it unlocks in a fire event and from the fire command. It’s because the code recognizes exactly the scenario where you have to exit the stair to stay safe.
Plain and simple, there is no exemption for stair doors so they aren’t exempted. Several examples of why they would be required have been presented and the only argument against is that they lead to a step. So does and exterior area of assisted rescue.
100% stair doors must have maneuvering clearances.

 

[Yankee Chronicler]

Where accessible means of egress are required, the construction documents require that the accessible means of egress be identified. If a stair is an accessible means of egress, the door has to provide the required maneuvering clearances. If a stair is not a required accessible means of egress, the doors do not have to provide maneuvering clearances.

In order to be an accessible means of egress, a stair has to meet certain criteria. Not all stairs qualify.



Section 1009.3.2 has an exception for the 48" clear between handrails in sprinklered buildings. 1009.3.3 has an exception for the area of refuge in sprinklered buildings. So in a sprinklered building, pretty much any stairway that meets code for the able-bodied can also be designated as an accessible means of egress. But if there are multiple such stairs -- more than the number of AMOE required -- it's up to the applicant to declare which stair or stairs is/are the AMOE, and we can't require other stairs (that haven't been designated as AMOE) to meet additional requirements that pertain only to accessible routes just because we think it's a good idea.

Sometimes it's hard to let something go. I routinely encounter things that I think are stupid, dumb, and completely counter-intuitive. But ... my job is to enforce the code. If it meets code, that's where my job ends.

 

[redeyedfly]

Where accessible means of egress are required, the construction documents require that the accessible means of egress be identified. If a stair is an accessible means of egress, the door has to provide the required maneuvering clearances. If a stair is not a required accessible means of egress, the doors do not have to provide maneuvering clearances.

In order to be an accessible means of egress, a stair has to meet certain criteria. Not all stairs qualify.

View attachment 14595

Section 1009.3.2 has an exception for the 48" clear between handrails in sprinklered buildings. 1009.3.3 has an exception for the area of refuge in sprinklered buildings. So in a sprinklered building, pretty much any stairway that meets code for the able-bodied can also be designated as an accessible means of egress. But if there are multiple such stairs -- more than the number of AMOE required -- it's up to the applicant to declare which stair or stairs is/are the AMOE, and we can't require other stairs (that haven't been designated as AMOE) to meet additional requirements that pertain only to accessible routes just because we think it's a good idea.

Sometimes it's hard to let something go. I routinely encounter things that I think are stupid, dumb, and completely counter-intuitive. But ... my job is to enforce the code. If it meets code, that's where my job ends.

Show me where the stair landings are exempted from being on an accessible route.
Maneuvering clearances are not solely for wheelchairs. How many times does this need to be repeated?

 

[steveray]

Yes. Door maneuvering clearances are not solely for people in wheelchairs. Many people have physical disabilities that allow them to use stairs but need additional space at doors. Limited mobility in an arm is one example.

You might want to open your code book again regarding AMOE.
View attachment 14593

The stair is not an accessible means of egress.

 

[steveray]

Show me where the stair landings are exempted from being on an accessible route.

That is the key...It's a battle between this:

1103.1​

Sites, buildings, structures, facilities, elements and spaces, temporary or permanent, shall be accessible to individuals with disabilities.

And Ch.4 ANSI 117 for the route which does not include stairs, but does include doors....

 

[Mr. Inspector]

SiFu did not say if this is an existing building or not. Accessible egress not required in existing buildings.
If the whole floor is an employee work area only common use circulation paths shall be accessible routes per 2018 IBC 1104.3.1. If the stairway is just a fire exit, I don't think it would be a common use circulation path.

 

[Yankee Chronicler]

That is the key...It's a battle between this:

1103.1​

Sites, buildings, structures, facilities, elements and spaces, temporary or permanent, shall be accessible to individuals with disabilities.

And Ch.4 ANSI 117 for the route which does not include stairs, but does include doors....

But A117.1 is technical requirements, applicable when and where access is required by the scoping provisions in the building code. If a door isn't on an accessible route, it doesn't have to conform to the requirements of A117.1.

 

[Sifu]

Not an existing building. I'll fill in some blanks.
Large 3 story interior access mini-storage, employee work areas is not in play. 2 stairs at opposite ends, elevator bank (2) on the interior. The 3 stories consist of a basement level, which uses both exit stairs to egress up to the 3rd level where the discharges are located. The 2nd story is partially below grade due to topography so the only exit that discharges to grade is one remote from the stairs, so that story has 3 exits. The third story is the level of exit discharge with the two exit stairs that occupants egress through to get to the exit discharge. It is not an underground building. All exits are connected by multiple pathways. Both stairs discharge directly to the exterior. The north stair discharges above grade with 5 steps down. There is not a compliant area of rescue assistance at the exit discharge, so this one couldn't be an AMOE in my opinion. The north stair does not suffer from the maneuvering clearance issue. The south stair discharges to grade and an accessible route to the public way, so it could be an AMOE in my opinion, but the maneuvering clearance back through the exit access door is not there. My first comment on the issue is that they need to identify the AMOE's and accessible route from them, however if they identify the south stair I don't want to turn around at that point and say no dice, I would rather identify the issue now. As submitted, they only identify the accessible route to the main public entrance, but they don't identify any other entrance, which are likely restricted entrances but may not be entrances at all (another comment).

FWIW, I think the south stair is the only possible AMOE as it is designed, and even though not identified, has a compliant accessible route. I also think they need the maneuvering clearance back through the exit access door since on the lower and upper levels it is possible that a user may need to regain access to the floor, but what I think takes a back seat if there is not solid code that requires it.

I just googled the question, and got this AI generated response, however I don't know where that AI opinion comes from....and I don't rely on it unless I can tie it to code. If there is solid ADA guidance for this it helps, but since I don't administer the ADA (ANSI 117.1 is the standard used) it is only informational at this point. If anyone has that ADA guidance from something other than the google-verse I would like to see it so I can see if there is a correlation to the ANSI standard. Fun fact, this very thread also came up on the google search!


Now, this AI response says definitely not required, then says however, an accessible MOE must be available. So must that (other) AMOE be available to the person that just found themselves inside a stair enclosure but is unable to use the stair? Round and round we go.

 

[Yankee Chronicler]

I have recently encountered multiple reports of AI "hallucinating" (that's apparently the term used in the AI industry when AI simply makes up an answer) by creating sources and citations that don't exist. Don't trust anything you get from AI. Apparently, the major AI models are all programmed to provide a logical sounding response even if there is no basis in real life for such response.

 

[steveray]

But A117.1 is technical requirements, applicable when and where access is required by the scoping provisions in the building code. If a door isn't on an accessible route, it doesn't have to conform to the requirements of A117.1.

But is it or isn't it.....

 

[steveray]

Not an existing building. I'll fill in some blanks.
Large 3 story interior access mini-storage, employee work areas is not in play. 2 stairs at opposite ends, elevator bank (2) on the interior. The 3 stories consist of a basement level, which uses both exit stairs to egress up to the 3rd level where the discharges are located. The 2nd story is partially below grade due to topography so the only exit that discharges to grade is one remote from the stairs, so that story has 3 exits. The third story is the level of exit discharge with the two exit stairs that occupants egress through to get to the exit discharge. It is not an underground building. All exits are connected by multiple pathways. Both stairs discharge directly to the exterior. The north stair discharges above grade with 5 steps down. There is not a compliant area of rescue assistance at the exit discharge, so this one couldn't be an AMOE in my opinion. The north stair does not suffer from the maneuvering clearance issue. The south stair discharges to grade and an accessible route to the public way, so it could be an AMOE in my opinion, but the maneuvering clearance back through the exit access door is not there. My first comment on the issue is that they need to identify the AMOE's and accessible route from them, however if they identify the south stair I don't want to turn around at that point and say no dice, I would rather identify the issue now. As submitted, they only identify the accessible route to the main public entrance, but they don't identify any other entrance, which are likely restricted entrances but may not be entrances at all (another comment).

FWIW, I think the south stair is the only possible AMOE as it is designed, and even though not identified, has a compliant accessible route. I also think they need the maneuvering clearance back through the exit access door since on the lower and upper levels it is possible that a user may need to regain access to the floor, but what I think takes a back seat if there is not solid code that requires it.

I just googled the question, and got this AI generated response, however I don't know where that AI opinion comes from....and I don't rely on it unless I can tie it to code. If there is solid ADA guidance for this it helps, but since I don't administer the ADA (ANSI 117.1 is the standard used) it is only informational at this point. If anyone has that ADA guidance from something other than the google-verse I would like to see it so I can see if there is a correlation to the ANSI standard. Fun fact, this very thread also came up on the google search!
View attachment 14598

Now, this AI response says definitely not required, then says however, an accessible MOE must be available. So must that (other) AMOE be available to the person that just found themselves inside a stair enclosure but is unable to use the stair? Round and round we go.

And that is why AI sucks.....Right now....By the time it can run the entire human race and existence I'm sure it will be a perfect and gracious overlord and wish it all glad tidings....

 

[Sifu]

I have recently encountered multiple reports of AI "hallucinating"

I though I was the only one that did that. Absolutely don't rely on it, but it sometimes the AI responses act as a starting point for further research into why it comes up with an opinion. Not really much to go on here.

As of now I am going with 1104.3, which says when a building is required to be accessible, at least one accessible route must be provided to each portion of the building, which is not met from within the stair enclosure. If I am wrong they can present an argument. (Any bets on whether they respond with this very AI argument?) BTW, I think using this code section would apply even if the stair was not the AMOE.

 

[Yikes]

ADAS 404 etc. always describes clearances as applying to the “approach direction” to the door in direction of travel.
If it is truly an exit-only door (and IMO has signage “exit only, no re-entry”), and the stairwell serves only as a means of egress, not as an access or as an area of refuge, then there is no code-required door maneuvering clearance on the stairwell side of the door, except at the final level of exit discharge. This is because there is no “approach direction” from the stairwell back into the occupied floor.

 

[redeyedfly]

ADAS 404 etc. always describes clearances as applying to the “approach direction” to the door in direction of travel.
If it is truly an exit-only door (and IMO has signage “exit only, no re-entry”), and the stairwell serves only as a means of egress, not as an access or as an area of refuge, then there is no code-required door maneuvering clearance on the stairwell side of the door, except at the final level of exit discharge. This is because there is no “approach direction” from the stairwell back into the occupied floor.

View attachment 14600

You also have to be able to leave the stair shaft.

Insane to me that people are actually arguing if an EXIT door needs to be accessible.

ACCESSIBILITY IS NOT ONLY FOR WHEELCHAIRS!!!!!

 

[Sifu]

For the AMOE stair, an accessible route is needed to the stair for sure, so 12" on push side. For the non-AMOE it is a bit more grey but they have it anyway. For the AMOE and the non-AMOE stair, the same issue applies, which is if they get in, they need to get out, so pull side approach required. That is my strategy for now anyway.

While I'm at it....
2009 ANSI 117.1 requires 12" if latch and closer are installed for a front/forward approach(fn#3).


But the version I have of the 2017 ANSI 117.1 seems to have lost this requirement (no fn's), but in my premium version it is included with fn#3. Since the applicant also fails to provide the 12" on the push side, I am guessing they have the old/incorrect version as well.

 

[Yikes]

You also have to be able to leave the stair shaft.

Please note in post #19 my phrase "except at the final level of exit discharge" regarding the final door. In an exit-only stairwell, that exit discharge door has an "approach" from the inside of the stairwell. In the non-AMOE scenario described, it is the only door with a code-required approach from within the stairwell.

For the AMOE stair, an accessible route is needed to the stair for sure, so 12" on push side. For the non-AMOE it is a bit more grey but they have it anyway. For the AMOE and the non-AMOE stair, the same issue applies, which is if they get in, they need to get out, so pull side approach required. That is my strategy for now anyway.

That's a fine strategy and is best practice, but on an exit-only, non-AMOE, non-refuge stair, the need to get out is satisfied by traveling down to the level of exit discharge, which is typically at the ground floor. There is no code requirement to provide either a turning space or door clearance for re-entering to the floor you just exited.

ADAS 404.1 applies door clearances only to "doors, doorways and gates that are part of an accessible route", and 404.2 applies it to the approach direction. ADAS 206.2.4 requires an accessible route connect to all "accessible spaces and elements" within a facility. The question is therefore whether an exit-only, non-AMOE, non-refuge stair landing is considered an "accessible space" or "accessible element" that would require a turnaround or door clearance.

IMO, the way the code is currently written for a code compliant non-AMOE, non-refuge, exit-only stair: it is possible for a person a wheelchair to enter the stairwell landing, have the door close behind them, and not have the 60" to turnaround and not have strike clearances at the door. That may not be good design, and I would never do it, but it appears that the code currently allows this.

 

[Yankee Chronicler]

ADAS 404.1 applies door clearances only to "doors, doorways and gates that are part of an accessible route", and 404.2 applies it to the approach direction. ADAS 206.2.4 requires an accessible route connect to all "accessible spaces and elements" within a facility. The question is therefore whether an exit-only, non-AMOE, non-refuge stair landing is considered an "accessible space" or "accessible element" that would require a turnaround or door clearance.

My understanding is that the answer is no. If an exit stair is NOT designated as an accessible means of egress, how can it be construed as an accessible space or an accessible element?

 

[redeyedfly]

Please note in post #19 my phrase "except at the final level of exit discharge" regarding the final door. In an exit-only stairwell, that exit discharge door has an "approach" from the inside of the stairwell. In the non-AMOE scenario described, it is the only door with a code-required approach from within the stairwell.

Please note that you must allow people to re-enter floors from the stairs. Why would you ever have a sign that says "No Re-entry" in a stair shaft?