Accessible egress

[gbhammer]

I have a question about travel distances and accessible egress.

A high school is adding a 6791 sq. ft. two story extension to a 7000 sq. ft. building. The addition is two stories and they will retrofit and sprinkle the whole space. The second floor has four stairwells and one elevator. There is an area of refuge 181’ from the most remote location and the next accessible egress, which is the elevator and a horizontal exit, is located 370’ away from the same remote location.

If accessibility is not taken into account they have more than enough exits within the required travel distances do they have to have the two required accessible exits meet the travel distance requirements?

 

[steveray]

1007.1 Accessible means of egress required.

Accessible means of egress shall comply with this section. Accessible spaces shall be provided with not less than one accessible means of egress. Where more than one means of egress is required by Section 1014.1 or 1018.1 from any accessible space, each accessible portion of the space shall be served by not less than two accessible means of egress.

Exceptions:

1. Accessible means of egress are not required in alterations to existing buildings.

2. One accessible means of egress is required from an accessible mezzanine level in accordance with Section 1007.3 or 1007.4.

3. In assembly spaces with sloped floors, one accessible means of egress is required from a space where the common path of travel of the accessible route for access to the wheelchair spaces meets the requirements in Section 1024.8.

Or...in other words...yes!

 

[RLGA]

With a sprinkler system, travel distance for a Group E occupancy is permitted to be up to 250 feet. Since the one exit with the area of refuge is 181 feet from the most remote point, the building appears to be in compliance. Only one exit needs to be within the prescribed maximum travel distance.

 

[gbhammer]

With a sprinkler system, travel distance for a Group E occupancy is permitted to be up to 250 feet. Since the one exit with the area of refuge is 181 feet from the most remote point, the building appears to be in compliance. Only one exit needs to be within the prescribed maximum travel distance.

That is what I thought. Now what about common path of egress only being allowed 75' for an E. The elevator and horizontal exit are on the same path as the area of refuge for 168' then another 190' + to two more eaccessible exits.

 

[steveray]

Why only one accessible MOE? If two are required per 1014 or 1018?

 

[gbhammer]

Why only one accessible MOE? If two are required per 1014 or 1018?

Not one accessible MOE, one within initial required travel distance.

 

[gbhammer]

My question is how do you rationalize that the disabled person has only one choice of paths insted of the two that are required in 1014.3.

 

[RLGA]

That is what I thought. Now what about common path of egress only being allowed 75' for an E. The elevator and horizontal exit are on the same path as the area of refuge for 168' then another 190' + to two more eaccessible exits.

If there are two distinct and separate paths that can be taken to reach the two exits, then they are not on a common path.

Why only one accessible MOE? If two are required per 1014 or 1018?

I didn't say only one accessible MOE is required; only that one accessible MOE needs to be within the required travel distance--just like any other required exit. Since two MOE are required, then at least two accessible MOE are required.

 

[steveray]

Got it......thought about it some more, makes sense, Then we would have to look at CPET for the accessible exits also.......

 

[gbhammer]

There is two distinct paths within 75' for the non-disabled occupant, however there is only one path for the first 168' for a disabled occupant.

 

[gbhammer]

Got it......thought about it some more, makes sense, Then we would have to look at CPET for the accessible exits also.......

CPET that is the ?

 

[steveray]

CPET that is the ?

Yep....when they have to have 2.....both must be accessible.....travel distance only talks about 1....I was getting confused also....CPET should let them choose from 2 accessible exits...

 

[RLGA]

There is two distinct paths within 75' for the non-disabled occupant, however there is only one path for the first 168' for a disabled occupant.

This is a tricky situation since the IBC seems to be gray in this area. Common path of egress travel (CPET) is definitely required for exits, but its application to accessible MOE is definitely unclear in my opinion. Section 1007.6 (2012 IBC) definitely requires that an area of refuge be within the required travel distance, but neither this section nor Section 1014.3 (for CPET) mention compliance with CPET requirements. In the interest of fairness and equality, I would require the accessible MOE also comply with CPET requirements. This may be a local interpretation issue.

 

[gbhammer]

Ok now here is the last rub, this particular building does not have to comply with 1014.3 because of 3411.6 exception #2. Accessible means of egress required by chapter 10 are not required to be provided in existing buildings and facilities.

The most remote locations are in the existing building, the accessible exits are all located in the existing portion of the building, the area of refuge is being created in an existing stairwell, and the only other work being done in the existing space is the sprinkler retrofit.

I am still curious in the event that I come across future submittals that may have this issue of the CPET requirements only meeting the needs of the able bodied occupant.

 

[steveray]

GB...I agree that the existing building codes greatly slack on accessibility...but watch for 3409.5.1(your code may differ) Alterations shall not reduce accessibility......if they are increasing an accessible exit distance, this may be an issue....

They are adding 14,000ft without adding an accessible MOE?

 

[gbhammer]

GB...I agree that the existing building codes greatly slack on accessibility...but watch for 3409.5.1(your code may differ) Alterations shall not reduce accessibility......if they are increasing an accessible exit distance, this may be an issue....They are adding 14,000ft without adding an accessible MOE?

I have wrangled with that line of reasoning and am not sure if it would apply because all the space they are adding does meet the requirements of chapter 10 and the existing space is getting an area of refuge that it did not have before. They chose the stairwell that they did because it was the only existing stair with the room for an area of refuge.

 

[Builder Bob]

Ok now here is the last rub, this particular building does not have to comply with 1014.3 because of 3411.6 exception #2. Accessible means of egress required by chapter 10 are not required to be provided in existing buildings and facilities.The most remote locations are in the existing building, the accessible exits are all located in the existing portion of the building, the area of refuge is being created in an existing stairwell, and the only other work being done in the existing space is the sprinkler retrofit.

I am still curious in the event that I come across future submittals that may have this issue of the CPET requirements only meeting the needs of the able bodied occupant.

Not sure that I agree with that reasoning, 2006 IBC -

3403.1 Existing buildings or structures. Additions or alterations to any building or structure shall comply with the

requirements of the code for new construction.

Additions or alterations shall not be made to an existing building or structure that will cause the existing building or structure to be in violation

of any provisions of this code. An existing building plus additions shall comply with the height and area provisions of Chapter 5. Portions of the structure not altered and not affected by the alteration are not required to comply with the code requirements for a new structure.

IMHO, the existing may not have to be altered or changed to provide for accessibility, but would have to maintain or enhance accessibility. The addition would have to comply with accessibility since it is new construction.

 

[JBI]

It might narrow down the answers if we knew what code and year to look at... Generally, make sure you are applying common path of egress travel correctly. Some folks seem to think it goes all the way to the door, when it actually stops once you have a choice. From there it is all simply travel distance. in a sprinklered E occupancy that can be a good distance.

 

[steveray]

BB....if you alter it it needs to comply, if you don't touch it , you can't make it worse by doing something else.....CT code (and I believe the current Icodes have an exception for not needing accessible MOE in an existing building...we here hold that to be if you install a new MOE in existing building, it shall comply, if it exists, it is allowed to remain, even if some alterations may effect it...So says the state....

Not sure that I agree with that reasoning, 2006 IBC - 3403.1 Existing buildings or structures. Additions or alterations to any building or structure shall comply with the

requirements of the code for new construction.

Additions or alterations shall not be made to an existing building or structure that will cause the existing building or structure to be in violation

of any provisions of this code. An existing building plus additions shall comply with the height and area provisions of Chapter 5. Portions of the structure not altered and not affected by the alteration are not required to comply with the code requirements for a new structure.

IMHO, the existing may not have to be altered or changed to provide for accessibility, but would have to maintain or enhance accessibility. The addition would have to comply with accessibility since it is new construction.

 

[gbhammer]

2009 IBC 3403.1 General. ...Alterations to an existing building or structure shall be made to ensure that the existing building or structure together with the addition are no less conforming with the provisions of this code than the existing building or structure was prior to the addition.

The existing building is only being altered by the sprinkler retrofit, and the addition of an area of refuge, that was not there before. So the alterations take the building in a direction that is safer, and I believe that they are not required to bring it up to new construction requirements. If I told them that they had to I believe they may simply remove the alterations.

 

[RLGA]

...A high school is adding a 6791 sq. ft. two story extension to a 7000 sq. ft. building...

I believe everyone is correct. This is more than a sprinkler retrofit per the quote above. The addition needs to comply with the IBC for new construction, which includes normal and accessiblle means of egress. The retrofit of a sprinkler system in the existing building is obviously okay and should not trigger any accessible upgrades, except for those required by the ADA.

Maybe posting some floor plans will help those in the dicussion to understanding the scope of the work.

 

[gbhammer]

Sorry I do not have an electronic copy of the plans.

 

[Builder Bob]

BB....if you alter it it needs to comply, if you don't touch it , you can't make it worse by doing something else.....CT code (and I believe the current Icodes have an exception for not needing accessible MOE in an existing building...we here hold that to be if you install a new MOE in existing building, it shall comply, if it exists, it is allowed to remain, even if some alterations may effect it...So says the state....

IMHO, the existing may not have to be altered or changed to provide for accessibility, but would have to maintain or enhance accessibility.

 

[pmarx]

Apologies for being late to the party. Also that I don’t presently have access to the 2009 IBC, only the modified version adopted by my home state so there may be a discrepancy between sections I reference and what you are operating under.

Did IBC make an exception regarding stairs and areas of refuge for buildings with NFPA 13 fire suppression (1007.3 Stairways and 1007.6 Areas of Refuge)? If so, I think “accessible” means of egress becomes a moot point. Likewise, 1007.2.1 doesn’t require an elevator for an accessible MOE for a two story building.

As I said, you may be operating under different requirements (and I could have missed another piece of information) but I think you may be able to disregard a concern for access to a particular exit.