California Building Code CBC 11B vs Chapter 10 ramp for 2nd exit

[swalton315]

In a new mixed-use apartment building type v-a over i-a. I am trying to get permitted in California I have a retail shell space that is 2150 SF. it has one entrance at grade but because of the slope of the site the 2nd means of egress is 40" above the floor level to exit at grade. If it ends up being all M occupancy it would require 2 "accessible means of egress". Per 1007.2 an open or enclosed stair is an accessible means of egress. However, the plan checker is saying that because it is only a 40" grade difference at the 2nd exit it is feasible to make that 2nd exit a ramp. so he is making that a requirement.

The plan checker is saying per Chapter 11B-206 of the CBC requires "accessible routes" shall be provided where required". And 11B-206.4.5 Tenant spaces "All entrances to each tenancy in a facility shall comply with Section 11B-404" I tried to argue the 2nd exit is only an exit not an entrance and thus only needs to be and "accessible means of egress" not an "accessible route" but he keeps saying 40" is not that much height to makeup but a 40' long ramp plus landings eats up a lot of real estate .

I've tried laying this all out in as clear a manner as possible. Any ideas on how to convince him? My fallback is to build a temporary ramp out of fire retardant treated wood and let the tenant improvement team hope for a different plan checker

 

[Builder Bob]

Make an exterior area of refuge..... 10 feet away from the building - i.e. smoking pad/gazebo,

 

[Yikes]

If seems to me the way you make an entrance only an exit is to add a sign: "EXIT ONLY", and to put locking hardware on the door (fire department can still have keyed handset at this door).

Per 11B-206.4.1 exception #1 below, you could put a 40" high set of stairs inside the tenant space, such that the exit door at the bottom landing is only serving this set of stairs. (I assume your 2nd exit is code-required by chapter 10, therefore exception #2 is of no use to you.)

11B-206.4.1 Entrances and exterior ground floor exits.

All entrances and exterior ground-floor exits to buildings and facilities shall comply with Section 11B-404.

Exceptions:

1. Exterior ground floor exits serving smoke-proof enclosures, stairwells, and exit doors serving stairs only shall not be required to comply with Section 11B-404.

2. Exits in excess of those required by Chapter 10, and which are more than 24 inches (610 mm) above grade shall not be required to comply with Section 11B-404. Such doors shall have warning signs complying with Section 11B-703.5, stating that they are not accessible.

Note that the very existence of the two exceptions above means that it is possible to have a door that is defined as an "exit" without necessarily also being called an "entrance".

From CBC 202 Definitions:

PUBLIC ENTRANCE. An entrance that is not a service entrance or a restricted entrance.

SERVICE ENTRANCE. An entrance intended primarily for delivery of goods or services.

RESTRICTED ENTRANCE. An entrance that is made available for common use on a controlled basis, but not public use, and that is not a service entrance.

 

[Yikes]

P.S. I meant locking hardware on the exterior side of the exit door - - obviously, NOT locking on the inside.

 

[cda]

Bring a rated corrior back to the front?? with a 2nd exit?

So there are no finish out plans for the first floor???

If not how does the plan checker know if a 2nd exit is even required??

Have you gone through the sections talking about needing only one exit based on travel and occupant load.????? I still have not figured it out, just know it is there.

 

[swalton315]

Yes there is no fit out plan yet but he wants to take the whole space as an M occupancy that would tip it into needing 2 exits. We offered to put the 2nd exit as an enclosed stair but he seems to think because it is possible to make a ramp work we should put a ramp in. He can't cite any code requirement but thinks because there is a site practicality test in chapter 11A (11A-50) there should be one in 11B?

 

[cda]

I love plan reviewers that have a crystal And design!!!

My crystal ball is in glass case "break only in case of emergency""

And I might hint of a solution.

With all that said do you think a second exit will be needed??

And if so are you trying to do it now instead of later?

 

[Yikes]

We offered to put the 2nd exit as an enclosed stair but he seems to think because it is possible to make a ramp work we should put a ramp in. He can't cite any code requirement but thinks because there is a site practicality test in chapter 11A (11A-50) there should be one in 11B?

The enclosed stair provides a code-compliant solution per 11B-206.4.1, exception #1. I challenge him to point out specifically where that design is not fully code compliant.

This has nothing to do with site impracticality. You could have a completely flat site, and if you had an exit door serving a stairwell it would not have to be accessible. If he disagrees, then he needs to take it up with BSC on the next code adoption cycle, not take it out on you and your project. Ask him to show you in their municipal code where the city modified the California Building Code to come up with this additional requirement.

I assume you are not using the back door for anything other than exit: not for parking access, not for a shortcut to other parts of the project, etc.

* CBC 11B-206.2.1 requires accessible routes from the public street, from parking, etc... "to the accessible building or facility ENTRANCE [not "exit"] they serve.

* CBC 11B-206.2.2 requires an accessible route between accessible elements within a site. But if we've already determined per 11B-206.4.1, exception #1 the exit door does not need to be accessible, then by definition it is not an accessible element and does not need to be on an accessible route.

Your site is 'practical'. The response of providing an in interior stair + landing to the 2nd exit door is likewise practical. End of story.