Accessory assembly use in a Business occupancy

[Nicole Brooks]

I have a training room in an office suite, the sf exceeds 750 sf. I provided panic hardware on all three doors that lead out of this room. I did not include panic hardware on the exit access doors out of the suite, nor did I upgrade the exit doors out of the existing building to include panic hardware. The inspector is telling me that I need to add panic hardware to the suite doors as well as the exit doors out of the building. I can't find anywhere in the code that says this is required, nor was it flagged when it went through plans review. In a theoretical sense, adding panic hardware to all the doors does not make any sense. What difference does it make if I have an office space that is over 50 people vs a office space that has a large training room that makes the whole occupant load over 50, as long as the proper number of exits are provided. They are all headed to the same exits. If anyone knows of any language that requires panic hardware to be applied to the entire egress path, please enlighten me!

 

[Tim Mailloux]

depeding on the furniture layout of the training room, I frequently calculate these types of spaces using a 1/20 classroom occupant load calculation. If you can do that it should resolve your accessory assembly issue.

 

[Nicole Brooks]

depeding on the furniture layout of the training room, I frequently calculate these types of spaces using a 1/20 classroom occupant load calculation. If you can do that it should resolve your accessory assembly issue.

I argued with the inspector and he passed it. I'm more interested in the answer on if panic hardware is required on all exit/exit access doors from this space to the exit. Do you know the answer to that?

 

[JPohling]

You do not say what code your working under but Yes, every door on the path out of the building will be required to be Panic Hardware if you have an A occupancy with over 50 occupants. In CA it is clearly required per CBC 2019

"Do I need panic hardware here?" - I Dig Hardware - Answers to your door, hardware, and code questions from Allegion's Lori Greene.

I Dig Hardware - Answers to your door, hardware, and code questions from Allegion's Lori Greene. | "Do I need panic hardware here?" | | This is THE most frequently-asked question that I receive. A specifier, supplier, architect, or end user has a retail, multi-family, office building, or other...

idighardware.com

What floor is this located on and are you able to have an "A" on that floor based upon your construction type?
Also an Assembly occupancy requires a 100#/SF live load for the floor.

 

[JPohling]

You do not say what code your working under but Yes, every door on the path out of the building will be required to be Panic Hardware if you have an A occupancy with over 50 occupants. In CA it is clearly required per CBC 2019

"Do I need panic hardware here?" - I Dig Hardware - Answers to your door, hardware, and code questions from Allegion's Lori Greene.

I Dig Hardware - Answers to your door, hardware, and code questions from Allegion's Lori Greene. | "Do I need panic hardware here?" | | This is THE most frequently-asked question that I receive. A specifier, supplier, architect, or end user has a retail, multi-family, office building, or other...

idighardware.com

What floor is this located on and are you able to have an "A" on that floor based upon your construction type?
Also an Assembly occupancy requires a 100#/SF live load for the floor.

OOPS forgot the code section............ CBC 2019 1010.1.10

 

[Nicole Brooks]

This is the 2018 Virginia State Construction Code. I believe they probably say the same thing: 1010.1.10 Panic and fire exit hardware: Swinging doors serving a Group H occupancy and swinging doors serving rooms or spaces with an occupant load of 50 or more in a Group A or E occupancy shall not be provided with a latch or lock other than panic hardware or fire exit hardware. My objection to requiring all exit and exit access doors in the path of egressto have panic hardware on them is because this is an accessory use to a business occupancy. The occupancy of the building remains Business. The code differentiates between the swinging doors of a group H (in which it requires all) to the swings doors of a Group A or E room or space with an occupant load of 50 or greater. I am reading it as panic hardware is just required on the doors serving the room / space, not the entire path of egress.

 

[Nicole Brooks]

OOPS forgot the code section............ CBC 2019 1010.1.10

This is the 2018 Virginia State Construction Code. I believe they probably say the same thing: 1010.1.10 Panic and fire exit hardware: Swinging doors serving a Group H occupancy and swinging doors serving rooms or spaces with an occupant load of 50 or more in a Group A or E occupancy shall not be provided with a latch or lock other than panic hardware or fire exit hardware. My objection to requiring all exit and exit access doors in the path of egressto have panic hardware on them is because this is an accessory use to a business occupancy. The occupancy of the building remains Business. The code differentiates between the swinging doors of a group H (in which it requires all) to the swings doors of a Group A or E room or space with an occupant load of 50 or greater. I am reading it as panic hardware is just required on the doors serving the room / space, not the entire path of egress. Oh, on the first floor.

Quote Reply
Report

 

[JPohling]

This is the 2018 Virginia State Construction Code. I believe they probably say the same thing: 1010.1.10 Panic and fire exit hardware: Swinging doors serving a Group H occupancy and swinging doors serving rooms or spaces with an occupant load of 50 or more in a Group A or E occupancy shall not be provided with a latch or lock other than panic hardware or fire exit hardware. My objection to requiring all exit and exit access doors in the path of egressto have panic hardware on them is because this is an accessory use to a business occupancy. The occupancy of the building remains Business. The code differentiates between the swinging doors of a group H (in which it requires all) to the swings doors of a Group A or E room or space with an occupant load of 50 or greater. I am reading it as panic hardware is just required on the doors serving the room / space, not the entire path of egress. Oh, on the first floor.

Quote Reply
Report

So back to the original question…”Do I need panic hardware on the stairwell doors in my apartment building, the main exit of my office building, or the emergency exit of my retail store?” These buildings would be considered Residential, Business, and Mercantile occupancies, so typically they would not require panic hardware on any doors unless there is an Assembly, Educational, or High Hazard area within the building with an occupant load of 50 or more (per the IBC) or 100 or more (per NFPA 101). Of course, panic hardware can be installed for convenience, security, or durability, even if it is not required by code.

 

[Nicole Brooks]

So back to the original question…”Do I need panic hardware on the stairwell doors in my apartment building, the main exit of my office building, or the emergency exit of my retail store?” These buildings would be considered Residential, Business, and Mercantile occupancies, so typically they would not require panic hardware on any doors unless there is an Assembly, Educational, or High Hazard area within the building with an occupant load of 50 or more (per the IBC) or 100 or more (per NFPA 101). Of course, panic hardware can be installed for convenience, security, or durability, even if it is not required by code.

So back to the original question…”Do I need panic hardware on the stairwell doors in my apartment building, the main exit of my office building, or the emergency exit of my retail store?” These buildings would be considered Residential, Business, and Mercantile occupancies, so typically they would not require panic hardware on any doors unless there is an Assembly, Educational, or High Hazard area within the building with an occupant load of 50 or more (per the IBC) or 100 or more (per NFPA 101). Of course, panic hardware can be installed for convenience, security, or durability, even if it is not required by code.

So I understand the reasoning of your last statements, but I feel this is an interpretation. I don't see anywhere in IBC where this is actually stated.

 

[JPohling]

Per the 2012 IBC commentary for 1008.1.10 and every single jurisdiction I have worked in across the country "interprets" this the same way.

Commentary: "Doors that are part of a means of egress from the locations listed in this section shall not be provided with a latch or lock unless it is panic hardware or fire exit hardware" "A" is listed, Accessory or not. the entire means of egress................

 

[Nicole Brooks]

Per the 2012 IBC commentary for 1008.1.10 and every single jurisdiction I have worked in across the country "interprets" this the same way.

Commentary: "Doors that are part of a means of egress from the locations listed in this section shall not be provided with a latch or lock unless it is panic hardware or fire exit hardware" "A" is listed, Accessory or not. the entire means of egress.............

I consulted a fire protection engineer and he had the commentary and provided it. You are right.

 

[JPohling]

So at this point you argued your point and the inspector gave in and you have provided a non compliant situation in terms of life-safety. If there is an issue that comes about by not having panics in the MOE you two will be named in the lawsuit and will not have a defense. That is some serious exposure.

 

[Nicole Brooks]

So at this point you argued your point and the inspector gave in and you have provided a non compliant situation in terms of life-safety. If there is an issue that comes about by not having panics in the MOE you two will be named in the lawsuit and will not have a defense. That is some serious exposure.

No, now that I know the correct answer, it will be remedied.

 

[Tim Mailloux]

No, now that I know the correct answer, it will be remedied.

OR.....you go back to my original suggestion and calculate the training room as a classroom, get the occupant load under 50 and your accessory occupancy goes by by.

 

[Nicole Brooks]

OR.....you go back to my original suggestion and calculate the training room as a classroom, get the occupant load under 50 and your accessory occupancy goes by by.

Unfortunately, the tenant moves in on Saturday, so no time to wait for a revision to the permit to be processed. Landlord is installing panic hardware as I type.

 

[JPohling]

depeding on the furniture layout of the training room, I frequently calculate these types of spaces using a 1/20 classroom occupant load calculation. If you can do that it should resolve your accessory assembly issue.

The only way we have been able to get that type of occupant load reduction to 1/20 is if they are fixed training tables.
If the tables and chairs are free to move, then 1/15.

 

[Tim Mailloux]

The only way we have been able to get that type of occupant load reduction to 1/20 is if they are fixed training tables.
If the tables and chairs are free to move, then 1/15.

I have never had an issue with this argument.....provided I am being honest and the space is truly intended for training. Office furniture isnt fixed and one could easily move that furniture out and move in a conference table at any time. should we calculate all offices at 1/15?

 

[JPohling]

I have never had an issue with this argument.....provided I am being honest and the space is truly intended for training. Office furniture isnt fixed and one could easily move that furniture out and move in a conference table at any time. should we calculate all offices at 1/15?

But your office example is not a valid argument as changing the furniture and subsequent occupant load factor would never yield a required second exit. The reason your attempting to alter the occupant load is to eliminate the second exit. In San Diego they have a published Technical Bulletin on occupant loads and will allow 1/50 net for computer training rooms with fixed workstations.