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AMOE exterior area for assisted rescue

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Sifu

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2018 IBC 1009.7 for an exterior area for assisted rescue. Given an exit stair with the exit discharge not at grade, using an exterior landing and stair to grade. The 2nd paragraph says that where the ED does not include an accessible route from the exit to the public way, an exterior area of assisted rescue shall be provided on the exterior landing. The exterior stairs are part of the ED. The commentary for this section then says you have two options: either the exterior area for assisted rescue, OR an interior area of refuge. Then the commentary double down by saying the interior area of refuge is not recommended.

I understand the logic in the commentary. If the stair is protected, then someone who makes it down the stair can wait out the hazard until someone comes for them, but it is not ideal as their presence may not be recognized as quickly as if they were sitting on the exterior landing. Of course the question would be how did they make it down the stair to the ED in the first place.....so per the commentary if an interior area of refuge is not provided an exterior area for assisted rescue is required. But that is not what the code language says. Code does not provide the option of the less than ideal interior area of refuge. I don't think the commentary is intending to get to the area of refuge option using by using 1009.3 because that section is for stairs between stories. What am I missing? I do not comment based on commentary, but my understanding of when and how to write a comment is influenced by it. My first reaction was to comment that they needed an exterior area for assisted rescue, then I read the commentary.
 
Maybe I found the path? 1009.2 says to use one or more of the 1 options. So #9 lists areas of refuge making it its own entity. So where the ED is not accessible I can use either and area of refuge inside the ED door, or an exterior area for assisted rescue outside the ED door. Makes sense except for how the user got to the bottom, and that the commentary tells us it isn't ideal.

Still, this language from 1009.7 would seem to leave no option:
Where the exit discharge does not include an accessible
route from an exit located on the level of exit discharge to a
public way, an exterior area of assisted rescue shall be provided
on the exterior landing
in accordance with Sections
1009.7.1 through 1009.7.4.
 
While I'm at this: If an interior exit stairway is an AMOE, can the user be directed out of the stairway back into the building at the level of ED to get to an accessible ED? While dispersal and travel distance aren't prescribed for an AMOE, I see this as a conflict with 1022.1 because the level of protection is reduced.
 
While I'm at this: If an interior exit stairway is an AMOE, can the user be directed out of the stairway back into the building at the level of ED to get to an accessible ED? While dispersal and travel distance aren't prescribed for an AMOE, I see this as a conflict with 1022.1 because the level of protection is reduced.
Going at this kind of backwards...Yes. they could use the 50% reentry from 1028 (in theory) but I

I think the 1009.7 language is assuming you made it through the discharge door and we all know with interior exits, that is not necessary......The stair IS the AMOE, even though it is not really spelled out well...

1009.3​

In order to be considered part of an accessible means of egress, a stairway between stories shall comply with Sections 1009.3.1 through 1009.3.3.

Nobody gives you guff for using ED? Geez.....
 
So I was puzzled why anyone should give me guff about using the "exit discharge", but couldn't find a reason, figured it was just another occurrence of me not getting something about the code that everyone else does. Then I realized the guff might be over the "ED" part. I laughed out loud.

Or, there is something obvious about this code I should get, but don't. If so I take my laugh back.
 
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