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All doors out of a bldg required to be code compliant exits?

akelly

Registered User
Joined
Oct 11, 2021
Messages
5
Location
Sacramento
So there is a minimum requirement for door count out of a space but say your building has 12 doors to the exterior (assume warehouse with several convenience doors) and only (2) are required by code for exiting. Do you find in some jurisdictions that you are required to make all of those doors code compliant exits... with signage and access to public way/area of refuge?
 
Yes. Usually.

It's a long time - age old - issue of does a building element that is not required have to meet the code requirements the same as if it was required. I submitted a code change to specifically say not some 15-18 years ago. It garnered quite a bit of discussion but was ultimately shot down. The interesting part of that it is the only proposal I've submitted that resulted in calls and emails after the hearings in support.

My observation is if you just design it that way - non-compliance - you might get away with it. My worst case - rails in a flat floor room for lines had to meet guard requirements for height and strength. Reverse, a play slide from entrance foyer to children's area in lower level if a church. It is a very steep ramp with no gate or guard or curb, and would be easy to fall, especially if sight impaired.

Some jurisdictions may be more lenient but, in my experience across the country, all of doors, stairs, corridors, ramps, railings, guards, etc. usually have to meet code as if they were required.
 
But if you don’t mark the door with a lighted exit sign, or any signs … seems like you would not need full compliance.
 
akelly, welcome to the forum!
It really helps is you tell us (1) where the project is located, so we know which code/jurisdiction is applicable, and (2) whether it is (a) new, (b) existing with no changes, or (c) existing with an addition or alteration proposed.

If you have a space that requires 2 exit doors but has 12 exit doors, then only 2 doors need to be made "code compliant" with the provisions IBC chapter 10 'Means Of Egress'. You certainly would not have exit signs on the other 10 doors if you don't intend to use them for exiting.

Since this was posted in the Accessibility forum, perhaps you meant to ask, "do the other 10 convenience doors in excess of those required by CBC chapter 10 need to be made mobility accessible per CBC chapter 11B?"

Assuming it is in Sacramento or somewhere in California, CBC 11B-206.4.1 for new buildings has a couple of exceptions:

1633994153577.png

ADA is a separate but related issue that you will want to consider as well. It will not be enforced by your city building official.
ADA Standard 206.4.1 says:
1633994535260.png

Let us know if your building is existing - - there may be a different response for existing vs. new.
 
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Do you find in some jurisdictions that you are required to make all of those doors code compliant exits... with signage and access to public way/area of refuge?
Not every door is intended to be code compliant as an exit door.
Example: A large open S-1 11,195 sq ft warehouse occupant load is only 24 but the Common Path of Travel requires 2 exits.

[F] 903.2.9 Group S-1.
An automatic sprinkler system shall be provided throughout all buildings containing a Group S-1 occupancy where one of the following conditions exists:
Less than 12,000 sq ft so no fire suppression required and none of the other conditions exist.

However Section 903.2.11.1 now has to be met

[F] 903.2.11.1 Stories without openings.
An automatic sprinkler system shall be installed throughout all stories, including basements, of all buildings where the floor area exceeds 1,500 square feet (139.4 m2) and where the story does not comply with the following criteria for exterior wall openings:

2. Openings entirely above the adjoining ground level totaling not less than 20 square feet (1.86 m2) in each 50 linear feet (15 240 mm), or fraction thereof, of exterior wall in the story on not fewer than one side. The required openings shall be distributed such that the lineal distance between adjacent openings does not exceed 50 feet (15 240 mm). The height of the bottom of the clear opening shall not exceed 44 inches (1118 mm) measured from the floor.

[F] 903.2.11.1.1 Opening dimensions and access.
Openings shall have a minimum dimension of not less than 30 inches (762 mm). Access to such openings shall be provided for the fire department from the exterior and shall not be obstructed in a manner such that fire fighting or rescue cannot be accomplished from the exterior.

Those minimum required dimensions make a 3.0 door the easiest and least expensive way to comply with 903.2.11.1.1. No they are not designed as exit doors and do not have to meet all the requirements of an exit door.
 
My take on this:

If the door is required to be an exit for some reason under the code, it must meet all the requirements for an exit door.
If the door is signed as an exit, even if it is not required by code, it has to function like an exit (occupants cannot be expected to spot a "fake" signed exit).
If it is what most people call a convenience door and is not signed as an exit, I don't care what you do with it, provided it does not violate other code provisions.
 
If it is what most people call a convenience door and is not signed as an exit, I don't care what you do with it, provided it does not violate other code provisions.
So it could be exact same model door as the required two with signs over them, and could have a dead bolt not operable without a key so no egress possible?
 
I see a situation where a building is built as a shell building with front and back exit door with purposed tenant remodeling that include separation walls. You may see it set up with 6-8 units and a tenant takes two spaces that would have four exit doors. Not all the doors would need to be treated as exit doors with exit signage but still could be used as egress doors. There's an IBC 1013 exception 2, in the code that sez an obvious entrance does not require an exit sign if approved by the BO.
 
So it could be exact same model door as the required two with signs over them, and could have a dead bolt not operable without a key so no egress possible?
Yup. It might as well be a wall for all I care.

This might be different in your codes, but our code regulates an "exit". An "exit" is a very specific thing under the code. Anything not meeting the definition of an exit, cannot be regulated as one. The only fly in the ointment on this is if someone signs a door that is not an exit as an exit. In that case, I would be comfortable requiring it to meet the provisions of an exit (there is language in the fire code for this), or allowing them to remove the sign (guess which happens more often!).

I feel like this issue is a lot like the ones where a building officials goes down the "what if" rabbit hole and regulates something based on what might happen rather than what it is.
 
I generally agree TMurray, but having been on design team on projects in many jurisdictions, the answer to the OPs question "Do you find in some jurisdictions that you are required to make all of those doors code compliant exits?" remains yes.

I guess if you only work in one or a relatively few jurisdictions, not much of an issue. You learn or decide what the interpretation is.
 
I generally agree TMurray, but having been on design team on projects in many jurisdictions, the answer to the OPs question "Do you find in some jurisdictions that you are required to make all of those doors code compliant exits?" remains yes.

I guess if you only work in one or a relatively few jurisdictions, not much of an issue. You learn or decide what the interpretation is.
I would imagine it would be quite frustrating to have an official obviously exceeding their legal authority. Do you fight them on this issue? Maybe, but what if they hold a grudge and get you back worse? But on the other side, if no one calls them on it, how does the problem get fixed? I have a hard time blaming contractors and designers for just complying sometimes.
 
There's usually bigger fish to fry than a few exit signs and besides, arguing with a building official is like wrestling with a pig in mud.........and I'm sure you know the rest.
 
I argue with BOs all the time and win. But in this case the BOs insisting all doors meet egress requirements have code to back them up.

1010.1Doors.
P​

Means of egress doors shall meet the requirements of this section. Doors serving a means of egress system shall meet the requirements of this section and Section 1022.2. Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section.

The rationale is that people don't check the code plans for the designed egress route in a fire event, they look for the nearest way to get out of the building.
 
1010.1 Doors. Means of egress doors shall meet the requirements of this section. Doors serving a means of egress system shall meet the requirements of this section and Section 1022.2. Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section.
 
A door is not a means of egress it is only one portion of the means of egress system and if you can't or don't comply with all of it then that door is simple that. A door that leads out of the building

[BE] EXIT. That portion of a means of egress system between the exit access and the exit discharge or public way. Exit components include exterior exit doors at the level of exit discharge, interior exit stairways and ramps, exit passageways, exterior exit stairways and ramps and horizontal exits.

[BE] EXIT DISCHARGE. That portion of a means of egress system between the termination of an exit and a public way.

[BE] MEANS OF EGRESS.
A continuous and unobstructed path of vertical and horizontal egress travel from any occupied portion of a building or structure to a public way. A means of egress consists of three separate and distinct parts: the exit access, the exit and the exit discharge.
 
Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section.

The extra doors are not provided for egress purposes...
 
Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section.

The extra doors are not provided for egress purposes...
Agreed. I think that section is trying to capture the doors that are not required, but have the exit sign above it anyway.
 
And this is why DPs get so frustrated with BOs. Just keep arguing a stupid point instead of admitting you're wrong.

The code can't get more clear. If you have a door that goes outside what else would you use it for? The intent is evident, the language is unambiguous. No landings required either?? And if it's more than 30" to grade on the other side, no problem according to another thread about windows.
 
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