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Assembly Function in Business Use Group

D

dsoedharmo

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Joined
Jun 5, 2023
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1
Location
Maryland
Hi all,
I am working on a tenant fit out for Business use that have rooms/areas with assembly function (e.g: conference room, lounge area, breakroom, etc.). Each of this room/area will have occupant load less than 49 people, but combination of all these assembly function rooms/areas will have occupant load more than 49 people.
My question is...will a panic hardware be required on exit doors from this suite?
I heard 2 different answers:
- 1st said that if none of your room with assembly function has more than 49 people then panic hardware will not be required.
- 2nd said (actually from code commentary)..." a door that provides means of egress for two or more such rooms (assembly) would require panic hardware or fire exit hardware where the combination of spaces has a total occupant load of 50 or more."
Thank you!
 
I don't have access to the Commentary at the moment, but the Commentary is not enforceable. My view is that if the occupant loads of these rooms don't exceed 50 individually, it's all a B occupancy classification. No panic hardware required.

I can't find justification for your second option in the language of the code.
 
dsoedharmo said:
- 2nd said (actually from code commentary)..." a door that provides means of egress for two or more such rooms (assembly) would require panic hardware or fire exit hardware where the combination of spaces has a total occupant load of 50 or more."
Click to expand...
The quoted commentary is under 1010.2.9 (Panic and Fire Exit Hardware.)

2021 IBC 1010.2.9 Panic and Fire Exit Hardware (emphasis added)
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.
Click to expand...
When the commentary says that panic hardware is required where the combined occupant load of the spaces is greater than 50, maybe they are considering the corridor serving those rooms as a “space” as referenced in 1010.2.9?
 
walker.t said:
The quoted commentary is under 1010.2.9 (Panic and Fire Exit Hardware.)


When the commentary says that panic hardware is required where the combined occupant load of the spaces is greater than 50, maybe they are considering the corridor serving those rooms as a “space” as referenced in 1010.2.9?
Click to expand...

Under that interpretation, any door serving 59 or more occupants opens to or from a "space," so we might as well say all exit doors in buildings with a total occupant load of 50 or more must have panic hardware.

But that's not what the code says.

In fact, in occupancy classifications using net square feet rather than gross, corridors have no occupant load.
 
Yankee Chronicler said:
Under that interpretation, any door serving 59 or more occupants opens to or from a "space," so we might as well say all exit doors in buildings with a total occupant load of 50 or more must have panic hardware.
Click to expand...
Just a suggestion trying to figure out the reasoning behind the commentary saying “where the combination of spaces has a total occupant load of 50 or more.”

Yankee Chronicler said:
But that's not what the code says.
Click to expand...
I think we’re in agreement, I did not understand 1010.2.9 to say the occupant load was the combination of the Group A or Group E rooms. If they intended “combined occupant load” then they could have easily said that.
 
Okay -

I'm home from the hospital and have access to my Commentary -- and I can think without distraction.

1010.2.9 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.
Click to expand...

Your situation isn't in an A or E occupancy. An office building (or story, or suite) is a B occupancy. Certain rooms such as meeting rooms may have their occupant load calculated using 15 s.f./person, but until the occupant load exceeds 50 those rooms are still classified as B occupancies. Therefore, 1010.2.9 does not apply.

xx
 
Regardless of code requirements, if you have high traffic load entering or exiting the build latching hardware is a hindrance
 
TheCommish said:
Regardless of code requirements, if you have high traffic load entering or exiting the build latching hardware is a hindrance
Click to expand...

I agree. However, I am licensed by my state to enforce the code, and I risk losing my license and my indemnification if I intentionally ignore the code and try to apply my own rules.
 
Yeah let's try and rephrase that. If a door could have a handle set on it that was latching and was permitted by the code to be the same, then if I wanted to put Panic Hardware on it that was not required, is that more restrictive or less restrictive than the code?
 
TheCommish said:
if I wanted to put Panic Hardware on it that was not required, is that more restrictive or less restrictive than the code?
Click to expand...
You would be more restrictive than the code. Standard lever hardware is the typical condition, panic hardware would be required to mitigate a greater hazard that is deemed to exist in certain occupancies and occupant loads. So if the space doesn’t require a panic door per code but you want to add the panic hardware, you have just imposed a more restrictive “requirement” (your desire) on the door.
 
TheCommish said:
Yeah let's try and rephrase that. If a door could have a handle set on it that was latching and was permitted by the code to be the same, then if I wanted to put Panic Hardware on it that was not required, is that more restrictive or less restrictive than the code?
Click to expand...

To me, "restrictive" indicates a requirement. Providing construction that exceeds the code isn't "restrictive," it's construction that exceeds the code. In other words, it complies.

Say you have an application for which the code allows 200 feet of exit access travel distance. Virtually no project has exit access travel distance that's exactly the maximum allowed by the code. So let's say the plan you're reviewing has a maximum exit access travel distance from the most remote point that's 167 feet. Would you call that "more restrictive" or would you just call it "compliant"?
 
Yankee Chronicler said:
but the Commentary is not enforceable.
Click to expand...
Actually, it kinda is.

jar546

Thread 'The Role of Commentary in Building Code Interpretation'

When a municipality adopts a building code, either independently or as mandated by a state statute, the specific code versions referenced in the statute and ordinance apply. For example, if a jurisdiction adopts the 2021 International Code Council (ICC) suite, including the IBC, IRC, IPC, IMC, IEBC, IECC, IPMC, and referenced standards like NFPA 70, those are the official, enforceable documents.

However, many of these codes have accompanying Commentary editions. These Commentaries mirror the code language but include explanations, background information, and practical examples to clarify...
 
jar546 said:
Actually, it kinda is.

jar546

Thread 'The Role of Commentary in Building Code Interpretation'

When a municipality adopts a building code, either independently or as mandated by a state statute, the specific code versions referenced in the statute and ordinance apply. For example, if a jurisdiction adopts the 2021 International Code Council (ICC) suite, including the IBC, IRC, IPC, IMC, IEBC, IECC, IPMC, and referenced standards like NFPA 70, those are the official, enforceable documents.

However, many of these codes have accompanying Commentary editions. These Commentaries mirror the code language but include explanations, background information, and practical examples to clarify...
Click to expand...
Only if the jurisdiction adopted the commentary version would it be enforceable.
 
I can only be thankful that at those times when either a designer or code official has been misled by the commentary, they have listened and agreed with me. It did take an ICC staff letter once, but they readily agreed based on code change history.
 
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