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Can a garage door count as an EERO?

J

jrharvey

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Joined
Aug 21, 2024
Messages
16
Location
North Carolina
Getting a really hard time on multiple projects from a reviewer. Dealing with townhomes on a very sloped site and the lowest level is 100% garage and submerged below ground like a basement. Because its townhomes both sides of the gargage are firewalls to the other units and the backside being below grade and the front side being all garage door. No room for another man door or window. Reviewer says this is a basement and requires an EERO and wont accept a garage door with an emergency release. What are your thoughts? I could appeal above but want to get your take on it first? I feel like a garage door can count so long as it has a method of manual open to meet R310.1.1. Code is 2018 NC residential code. Sections below....


R310.1 Emergency Escape and Rescue Opening Required
Basements, habitable attics and every sleeping room shall have not less than one operable emergency escape and rescue opening. Where basements contain one or more sleeping rooms, an emergency escape and rescue opening shall be required in each sleeping room. Emergency escape and rescue openings shall open directly into a public way, or to a yard or court that opens to a public way.
Exception: Storm shelters and basements used only to house mechanical equipment not exceeding a total floor area of 200 square feet (18.58 m2).


R310.1.1 Operational Constraints and Opening Control Devices
Emergency escape and rescue openings shall be operational from the inside of the room without the use of keys, tools or special knowledge. Window opening control devices complying with ASTM F2090 shall be permitted for use on windows serving as a required emergency escape and rescue opening.


R310.3 Emergency Escape and Rescue Doors
Where a door is provided as the required emergency escape and rescue opening, it shall be permitted to be a side-hinged door or a slider. Where the opening is below the adjacent ground elevation, it shall be provided with a bulkhead enclosure.
 
Yankee Chronicler said:
What's the method of emergency release? Can a child reach it? Can a child open the garage door unassisted?
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Depends on the age and height of the child I guess. My thought is much like a tall window a toddler or even 4 year old couldnt escape unassisted or without standing on something. Origonally I was thinking typical pull chord release but maybe there are other options for emergency release. The force required to open a single hung is often as much sometimes more than lifiting a garage door.
 
Mr. Inspector said:
They do make garage doors with swinging doors built in them.
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You mean something like this?

22560949c6492c903a06bbc4d312aa74.jpg
 
jrharvey said:
Depends on the age and height of the child I guess. My thought is much like a tall window a toddler or even 4 year old couldnt escape unassisted or without standing on something. Origonally I was thinking typical pull chord release but maybe there are other options for emergency release. The force required to open a single hung is often as much sometimes more than lifiting a garage door.
Click to expand...

That's what my overhead garage door has. The cord hangs down maybe a couple of feet. I'm 6'-1" tall and I can reach it. My late wife was 5'-4" tall and for her it was a struggle. There's no way I would approve that as an EERO from the garage.

The weight of the door is also an issue. Overhead doors are equipped with springs to assist in overcoming the weight of the door when opened manually, but I'm not aware of any standards or code limitations addressing a maximum force allowed to open an overhead garage door manually.
 
I guess what is driving me nuts is the common sense issue here. If the garage was not below grade there is no requirement that there be any kind of EERO. You can walk up stairs through the home to get to a normal egress. Since its half below grade the very same garage requires an EERO just because its lumped in with the term "basement". You cant walk up stairs through the home to egress the same as the previous scenario? If say someone were truly trapped in a garage in case of emergency I logically dont know why an above grade is considered safer unless you can take an axe through the exterior sheathing and pop out the other side of the wall. Just seems like a to the book understanding to me and not based on logic or common sense. I just think its clearly an oversight or a reviewer holding tight to the word, not the actual intent of the code.
 
Last edited:
If the only basement is the garage, I would attempt to argue that it is not a basement …to some extent based on code saying you cannot egress through a basement…
 
steveray said:
If the only basement is the garage, I would attempt to argue that it is not a basement …to some extent based on code saying you cannot egress through a basement…
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I was origonally thinking this exactly since there is no requirement to have an EERO if the garage was at grade and not below. Even if you argue the stairs if you have a garage with a tall crawl its still not requiring an EERO. I just think its an oversight or misinterpretation of intent. The issue is that the definition of basement and the reviewer taking it way too broad and litterally.
 
Does this area meet the definition of a basement? Is it possible that the average finished ground level is low enough that it's technically not a basement?

[RB]BASEMENT. A story that is not a story above grade plane (see “Story above grade plane”).

[RB]STORY ABOVE GRADE PLANE. Any story having its finished floor surface entirely above grade plane, or in which the finished surface of the floor next above is either of the following:
  1. More than 6 feet (1829 mm) above grade plane.
  2. More than 12 feet (3658 mm) above the finished ground level at any point.
[RB]STORY. That portion of a building included between the upper surface of a floor and the upper surface of the floor or roof next above.

[RB]GRADE PLANE. A reference plane representing the average of the finished ground level adjoining the building at all exterior walls. Where the finished ground level slopes away from the exterior walls, the reference plane shall be established by the lowest points within the area between the building and the lot line or, where the lot line is more than 6 feet (1829 mm) from the building between the structure and a point 6 feet (1829 mm) from the building.
 
R311.1 Means of Egress
Dwellings shall be provided with a means of egress in accordance with this section. The means of egress shall provide a continuous and unobstructed path of vertical and horizontal egress travel from all portions of the dwelling to the required egress door without requiring travel through a garage. The required egress door shall open directly into a public way or to a yard or court that opens to a public way.

R311.2 Egress Door
Not less than one egress door shall be provided for each dwelling unit. The egress door shall be side-hinged, and shall provide a clear width of not less than 32 inches (813 mm) where measured between the face of the door and the stop, with the door open 90 degrees (1.57 rad). The clear height of the door opening shall be not less than 78 inches (1981 mm) in height measured from the top of the threshold to the bottom of the stop. Other doors shall not be required to comply with these minimum dimensions. Egress doors shall be readily openable from inside the dwelling without the use of a key or special knowledge or effort.
 
mark handler said:
R311.1 Means of Egress
Dwellings shall be provided with a means of egress in accordance with this section. The means of egress shall provide a continuous and unobstructed path of vertical and horizontal egress travel from all portions of the dwelling to the required egress door without requiring travel through a garage. The required egress door shall open directly into a public way or to a yard or court that opens to a public way.

R311.2 Egress Door
Not less than one egress door shall be provided for each dwelling unit. The egress door shall be side-hinged, and shall provide a clear width of not less than 32 inches (813 mm) where measured between the face of the door and the stop, with the door open 90 degrees (1.57 rad). The clear height of the door opening shall be not less than 78 inches (1981 mm) in height measured from the top of the threshold to the bottom of the stop. Other doors shall not be required to comply with these minimum dimensions. Egress doors shall be readily openable from inside the dwelling without the use of a key or special knowledge or effort.
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Hi Mark, The level above the garage is the main entry level with an egress door at grade. No space has to exit through the garage. The lowest level is 100% garage and nothing else. See the site slopes a full story from front to back of the units. I would post a picture but I cant seem to right now. Basically we meet R311.1 and R311.2. The main argument from the reviewer is that the garage level which has nothing but garage meets the definition of a basement whether it is a garage or not and must have an EERO since it doesnt meet the exception. My thought is just thinking logically this doesnt make sense because of the post #9 and #11 that I mentioned above.
 
jrharvey said:
R310.3 Emergency Escape and Rescue Doors
Where a door is provided as the required emergency escape and rescue opening, it shall be permitted to be a side-hinged door or a slider.
Click to expand...
Just commenting on this code text above:

The 2018 IRC definition of EMERGENCY ESCAPE AND RESCUE OPENING is "An operable exterior window, door or similar device that provides for a means of escape and access for rescue in the event of an emergency."

The above text from R310.3 uses the permissive language "shall be permitted". Therefore it is only providing options, not imposing requirements.

As such, while I would not consider an overhead door to be a slider (common usage is a door that slides side to side), there is no blanket prohibition on an overhead door being an EERO.

Cheers, Wayne

P.S. There is still the question of whether the controls for a typical overhead door would require "special knowledge" as prohibited by R310.1.1. That is mostly subjective, as knowledge that seems special to you may seem commonplace to me.
 
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2018 IRC
R104.10 Modifications.
Where there are practical difficulties involved in carrying out the provisions of this code, the building official shall have the authority to grant modifications for individual cases, provided the building official shall first find that special individual reason makes the strict letter of this code impractical and the modification is in compliance with the intent and purpose of this code and that such modification does not lessen health, life and fire safety or structural requirements. The details of action granting modifications shall be recorded and entered in the files of the department of building safety.

R104.11 Alternative materials, design and methods of construction and equipment.
The provisions of this code are not intended to prevent the installation of any material or to prohibit any design or method of construction not specifically prescribed by this code. The building official shall have the authority to approve an alternative material, design or method of construction upon application of the owner or the owner’s authorized agent. The building official shall first find that the proposed design is satisfactory and complies with the intent of the provisions of this code, and that the material, method or work offered is, for the purpose intended, not less than the equivalent of that prescribed in this code in quality, strength, effectiveness, fire resistance, durability and safety. Compliance with the specific performance-based provisions of the International Codes shall be an alternative to the specific requirements of this code. Where the alternative material, design or method of construction is not approved, the building official shall respond in writing, stating the reasons why the alternative was not approved.

2018 IBC
1010.1.2 Door swing.
Egress doors shall be of the pivoted or side-hinged swinging type.

Exceptions:

1. Private garages, office areas, factory and storage areas with an occupant load of 10 or less.

If it is okay for an IBC R occupancy it should be okay for an IRC occupancy. Is there a difference in your state if you use the IRC or the IBC?
If not then use the IBC and your design would be compliant.
 
mtlogcabin said:
2018 IRC
R104.10 Modifications.
Where there are practical difficulties involved in carrying out the provisions of this code, the building official shall have the authority to grant modifications for individual cases, provided the building official shall first find that special individual reason makes the strict letter of this code impractical and the modification is in compliance with the intent and purpose of this code and that such modification does not lessen health, life and fire safety or structural requirements. The details of action granting modifications shall be recorded and entered in the files of the department of building safety.

R104.11 Alternative materials, design and methods of construction and equipment.
The provisions of this code are not intended to prevent the installation of any material or to prohibit any design or method of construction not specifically prescribed by this code. The building official shall have the authority to approve an alternative material, design or method of construction upon application of the owner or the owner’s authorized agent. The building official shall first find that the proposed design is satisfactory and complies with the intent of the provisions of this code, and that the material, method or work offered is, for the purpose intended, not less than the equivalent of that prescribed in this code in quality, strength, effectiveness, fire resistance, durability and safety. Compliance with the specific performance-based provisions of the International Codes shall be an alternative to the specific requirements of this code. Where the alternative material, design or method of construction is not approved, the building official shall respond in writing, stating the reasons why the alternative was not approved.

2018 IBC
1010.1.2 Door swing.
Egress doors shall be of the pivoted or side-hinged swinging type.

Exceptions:

1. Private garages, office areas, factory and storage areas with an occupant load of 10 or less.

If it is okay for an IBC R occupancy it should be okay for an IRC occupancy. Is there a difference in your state if you use the IRC or the IBC?
If not then use the IBC and your design would be compliant.
Click to expand...

Thank you for the response. Yes agree with all that. In NC there are differences between the NCRC and the NCBC. It wouldnt be practical to make the switch. Reviewer isnt requiring an egress door. He is requiring an Emergency escape and rescue opening either a door or window. I think the big thing the reviewer is getting stuck on is the fact that the NCRC states an EERO is required for basements even though its not required for garages specifically. Because one of the walls is below grade he is stating by definition it is a basement. At grade garage ok, below grade garage not ok. I think he is just stuck on the strict word of the language.
 
Unfortunately NC redefines Basement as "That portion of a building that is partly or completely below grade." This might be for uniformity with FEMA flood zone regulations.
 
Paul Sweet said:
Unfortunately NC redefines Basement as "That portion of a building that is partly or completely below grade." This might be for uniformity with FEMA flood zone regulations.
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There has to be more to it than that. What qualifies "partly"? This is so openended that there are lots of basements that are hardly basements.
 
Paul Sweet said:
Unfortunately NC redefines Basement as "That portion of a building that is partly or completely below grade." This might be for uniformity with FEMA flood zone regulations.
Click to expand...
It has one more sentence after that definition:
[RB] BASEMENT. That portion of a building that is partly or completely below grade . (see "Story above grade plane").

[RB] STORY ABOVE GRADE PLANE.
Any story having its finished floor surface entirely above grade plane, except that a basement shall be considered as a story above grade plane where the finished surface of the floor above the basement meets any one of the following:
  1. Is more than 6 feet (1829 mm) above grade plane.
  2. Is more than 6 feet (1829 mm) above the finished ground level for more than 50 percent of the total building perimeter.
  3. Is more than 12 feet (3658 mm) above the finished ground level at any point.
 
Thank you everyone. I think the garage door with the man door built in is a good solution, just need to find something more local as everything I am finding is in Canada.

So after talking with the reviewer I think I have confirmed that if I can get the level above to be more than 12' above grade then he will not consider it a basement by definition and not require an EERO. So that is a solution but Im going to be honest here that as an architect, not a code reviewer this kind of thing drives me absolutely insane. Can anyone feel my pain here or am I the crazy one? Adding additional height to the retaining wall just to avoid a technicality or lack of clarification in the code just seems absolutely insane right? Now I have to consult with the owner about why he has to pay more out of pocket for this reason. The worst part is this does absolutely nothing to make the building safer. The garage suddenly isnt safer due to the fact its a foot taller. I just really hate this kind of stuff throwing money at things with litterally zero practical results.
 
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