2018 IBC 1009.2.1 - Elevators Required (Accessible Means of Egress)

[SH225]

2018 IBC 1009.2.1 says, "In buildings where a required accessible floor is four or more stories above or below a level of exit discharge, not less than one required accessible means of egress shall be an elevator complying with Section 1009.4. Therefore, if we have a five-story building, this section requires an accessible elevator per 1009.4, which requires standby power. Although the code doesn't exactly say so here, it appears that requirement applies on all the upper levels. Now suppose we have two levels of parking in the basement, below the level of exit discharge. Does 1009.2.1 require the accessible elevator in the basement, too?

For the upper floors we have an exception for floors provided with sprinklers and a horizontal exit, but the exception is limited to floors at or above the levels of exit discharge. Without that exception for a horizontal exit on floors below the exit discharge, and assuming we do not have an accessible exit ramp in the basement, are we required to provide an elevator with standby power in the two-level basement?

 

[cda]

Welcome

Give it a few days for great answers

 

[SH225]

Welcome

Give it a few days for great answers

Thank you for the welcome.

 

[RLGA]

Do not confuse accessible elevators with elevators used for an accessible means of egress. Accessible elevators are required for all levels that are required to be accessible whether they are used as an accessible means of egress or not. Those accessible elevators, however, are not required to be an accessible means of egress unless they are needed for an accessible floor on the fifth or higher story, or for a story that is four stories or more below the level of exit discharge.

If using Exception 1, then the elevator is not required to be an accessible means of egress. However, this would not apply to levels below the level of exit discharge if the number of levels below is four or more--you would still need to make the elevator an accessible means of egress.

If there are no more than three levels below the level of exit discharge and the levels above the level of exit discharge comply with Exception 1, then the elevator is not required to be an accessible means of egress.

 

[SH225]

Do not confuse accessible elevators with elevators used for an accessible means of egress. Accessible elevators are required for all levels that are required to be accessible whether they are used as an accessible means of egress or not. Those accessible elevators, however, are not required to be an accessible means of egress unless they are needed for an accessible floor on the fifth or higher story, or for a story that is four stories or more below the level of exit discharge.

If using Exception 1, then the elevator is not required to be an accessible means of egress. However, this would not apply to levels below the level of exit discharge if the number of levels below is four or more--you would still need to make the elevator an accessible means of egress.

If there are no more than three levels below the level of exit discharge and the levels above the level of exit discharge comply with Exception 1, then the elevator is not required to be an accessible means of egress.

Thank you for the reply. I read it several times and couldn't decide whether the code tells us to consider the levels below the level of exit discharge separately from the levels above the level of exit discharge. In the commentary, it shows a separate section diagram for a below-ground example and an above-ground example, but nothing clicked with me to confirm they're considered separately in this requirement.

 

[icatalyst]

With all due respect to Ron Geren, whose posts have always been essential for my understanding of the code, I must take exception to the claim that using Exception 1 to Section 1009.2.1 exempts 1, 2, or 3 basements from having the elevator be the primary accessible means of egress.
The use of the word "or" in the language makes it clear that is not the intent of the code: "In buildings where a required accessible floor or occupied roof is four or more stories above or below a level of exit discharge. . ." [emphasis added]. The way this has to be read is that, once a building has four or more stories above the level of exit discharge, an elevator must be the accessible means of egress for the entire building, including for however many basement levels there might be. And vice versa, once a building has four or more stories below the level of exit discharge, then any number of floors above the level of exit discharge must also have the elevator as the accessible means of egress, although for sprinklered floors at or above the level of exit discharge, Exception 1 can be utilized to provide a horizontal exit instead.
While the ICC illustrations may not have the same weight as the written words, it is important to observe that Commentary Figure 1009.2.1 shows these two types of buildings with separate drawings: "a)" (without a basement) and "b)" (with a 2nd floor above the level of exit discharge). These are not the same building, but rather two examples of two different buildings; in each case, the illustration is of a single building. The 5th Floor of "a)" and the 4th Basement of "b)" are, respectively, the triggers for each of those two separate buildings to comply with the elevator requirement. True, a 4-story building with 3 basements would be exempt, but once the 5th floor is added or the 4th basement excavated, the code provision is triggered for the entire building, all upper floors and/or basements included.

 

[RLGA]

With all due respect to Ron Geren, whose posts have always been essential for my understanding of the code, I must take exception to the claim that using Exception 1 to Section 1009.2.1 exempts 1, 2, or 3 basements from having the elevator be the primary accessible means of egress.
The use of the word "or" in the language makes it clear that is not the intent of the code: "In buildings where a required accessible floor or occupied roof is four or more stories above or below a level of exit discharge. . ." [emphasis added]. The way this has to be read is that, once a building has four or more stories above the level of exit discharge, an elevator must be the accessible means of egress for the entire building, including for however many basement levels there might be. And vice versa, once a building has four or more stories below the level of exit discharge, then any number of floors above the level of exit discharge must also have the elevator as the accessible means of egress, although for sprinklered floors at or above the level of exit discharge, Exception 1 can be utilized to provide a horizontal exit instead.
While the ICC illustrations may not have the same weight as the written words, it is important to observe that Commentary Figure 1009.2.1 shows these two types of buildings with separate drawings: "a)" (without a basement) and "b)" (with a 2nd floor above the level of exit discharge). These are not the same building, but rather two examples of two different buildings; in each case, the illustration is of a single building. The 5th Floor of "a)" and the 4th Basement of "b)" are, respectively, the triggers for each of those two separate buildings to comply with the elevator requirement. True, a 4-story building with 3 basements would be exempt, but once the 5th floor is added or the 4th basement excavated, the code provision is triggered for the entire building, all upper floors and/or basements included.

@icatalyst, the purpose of requiring an elevator to be an accessible means is to serve the stories that are considered too high or too far below the level of exit discharge. If a five-story building with a three-story basement is served by a single elevator, then the elevator must be an accessible means of egress and have the required standby power. However, if the three-story basement is served separately with its own elevator from that of the five stories above, the elevator serving the basement stories only would not need to be considered an accessible means of egress with standby power--only the elevator serving the five stories above the grade plane. If one elevator serves all eight floors and another elevator only serves the five stories above the grade plane, either elevator can be made the accessible means of egress.

 

[icatalyst]

Ron Geren - thank you for the well-considered reply, but unfortunately neither the ICC nor the U. S. Access Board agrees.

In its Commentary about why Exception 1 to Section 1009.2 cannot be applied to basements, the ICC states that it is not the distance down to reach someone in peril but rather the lack of windows:

This exception does not apply to floor levels below the level of exit discharge, since such levels are typically below grade and do not have the added advantage of exterior openings that are available for fire-fighting or rescue purposes.​

And in its illustration for Accessible Means of Egress, the U.S. Access Board notes that, while a horizontal exit can be used to avoid the requirement for the elevator to be on standby power, an unspecified number of “floors below the level of exit discharge” are excluded – see the attached Figure from the U.S. Access Board.

One would have thought that if one, two or even three floors could be included in this exception, the U.S. Access Board would have mentioned it, but instead their silence speaks volumes, implying that even a single floor below the level of exit discharge must have an elevator with standby power.

Finally, matching the concerns of what SH225 originally posted, my office has recently been required by the AHJs in two separate and unrelated jurisdictions – one in Northern California, one in Southern California – to address how a disabled occupant could egress from an underground garage, on housing projects that were both 5-story Type III-A with horizontal exits on the upper floors and with just a single Type I-A basement (without an emergency generator to provide standby power).

Of course, a $500K genset could solve all of these problems, but that is an expense that most non-high rise projects will not shell out for if there is any other solution. The garages do of course have ramps, but they are always steeper than 1:12 to get down to a basement . . . and even if they were held to a 1:20 slope, the vertical rise of more than 30” would trigger the need for a flat landing.

 

[RLGA]

I never stated that Exception 1 applied to basements.

There are two triggers that require at least one elevator to be considered an accessible means of egress with standby power:

1. Four or more stories above the level of exit discharge; or,
2. Four or more stories below the level of exit discharge.

If the first trigger exists, but the second trigger does not, then Exception 1 can effectively negate the first trigger if all stories above the level of exit discharge have horizontal exits. There is no condition that requires the basement stories to have an accessible means of egress by elevator. Now, I admit the code does not directly support this interpretation, but it also does not directly prohibit it either—it is a matter of interpretation.

The Commentary also does not address the specific condition mentioned above. The requirement for an accessible means of egress via elevator is a condition on distance and access per the Commentary. The stories above the level of exit discharge do have firefighter access from the exterior to rescue people from stories; whereas, the stories below the level of exit discharge do not. Thus, Exception 1 is permitted for only the stories above the level of exit discharge.

The distance and access to occupants on stories below the level of exit discharge does not change just because the occupants above the level of exit discharge are afforded the exception. For example, let’s assume a building only had three stories below the level of exit discharge and no stories above the level of exit discharge. How does the situation differ for occupants in those basement stories from that of the occupants within the same number of basement stories in a building with stories above the level of exit discharge?

The reason the accessibility standards (i.e., ADA and ABA) do not address accessibility means of egress in any great detail is that they default to the building code, specifically, the 2003 IBC or 2000 IBC with the first supplement.