E occupancy egress code changes.

[Beniah Naylor]

Would anyone be interested in drafting or helping to draft code change(s) to egress requirements for schools to help address active shooter scenarios?

I hadn't really thought much about this aspect before, but obviously the topic in general has been a hot one this week.

Currently, the FBI recommended Run Hide Fight tactic is the training that basically everyone receives when it comes to active shooter scenarios. I included it in the PDF here. I'm not going to debate if that is the most effective tactic, but that is the training everyone has.

The first and most survivable tactic, "Run" means to completely escape the area where the shooter is or will be. This is great in a mall, or even many churches, because you have egress paths that get you outside quickly and you can get clear of the area. The problem with that is that the egress path for many classrooms includes corridors, common paths of travel, exit access passageways, and generally funneling people who are egressing down an egress path. The shooter expects people to try to escape, so they block the means of egress. This is somewhat exacerbated by the extra "bonuses" you get by installing sprinkler systems - you figure they will keep the fire knocked down for longer, and give you more time to egress, so you can give a little on egress issues. However, fire is not the only issue to consider.

So then, the victims are left trapped and barricaded into their classrooms, (Hiding), and then Fighting when that doesn't work. Odds are much worse at this point, especially if no one has equivalent weapons to the terrorist(s). If someone with an equivalent weapon is there, everyone else still needs to escape and get out of their way, so the same issues apply.

I am wanting to kick around ideas to maybe shorten travel distances in E occupancies, maybe require EEROs in more classrooms, etc. Like a rabbit warren approach, if the predator comes in one hole, you can just retreat out of another. Obviously, they should be guarded against becoming an entrance for the terrorist to utilize.

 

[steveray]

Go back to putting an exit discharge door from every classroom?....Like they used to before the sprinkler gimmie? This does not need to be a code change...Good design can solve this.....

 

[mtlogcabin]

We have a few two story schools so that is not possible.
There are code sections that are not mandatory but could be used to reduce the risk if the schools where willing to spend the money to implement them.
Emergency voice/alarm communication systems, Mag holders on all classroom doors with electronic locks initiated from the office that would secure the students in the classroom. Access to the school through only one or two entries that have electronically controlled access from the office. These are just a few ideas

 

[Beniah Naylor]

I recognize that after a disaster, there is often a knee-jerk reaction to just "do something", and that reaction is not always well thought out and causes more problems than it fixes. I really don't want to break chapter 10 in some way in the interest of just "doing something".

However, I think we need to change the way we think about egress in schools. NFPA's report "Structure Fires in Schools" from 2014 to 2018 shows that there is an annual average of 1 civilian death, 39 civilian injuries, and $37 million in direct property damage. https://www.nfpa.org/News-and-Resea...ng-and-Life-Safety/Structure-fires-in-schools.

I didn't try very hard to pull up the stats for deaths from mass shooter/mass casualty events in schools- all the stats I found were related to "school shootings" and the data was skewed by drug related shootings, accidental discharges, etc. However, we all know that the annual death toll from mass shooter/mass casualty events in schools is much higher than the fire stats quoted above - I would say we easily pass 20 deaths a year from that cause, based on my own memory of current events.

We have the fire part down. We understand how to prevent structural collapse. We are very good at those things. It is my opinion that we need to address a higher threat in the way that we as code officials, writers, and administrators have control over. /end rant/

 

[Beniah Naylor]

Go back to putting an exit discharge door from every classroom?....Like they used to before the sprinkler gimmie? This does not need to be a code change...Good design can solve this.....

I like this, may not be applicable everywhere, but it is a good start.

We have a few two story schools so that is not possible.
There are code sections that are not mandatory but could be used to reduce the risk if the schools where willing to spend the money to implement them.
Emergency voice/alarm communication systems, Mag holders on all classroom doors with electronic locks initiated from the office that would secure the students in the classroom. Access to the school through only one or two entries that have electronically controlled access from the office. These are just a few ideas

How can we address egress from multistory schools? My main thing is that I think locking down a room full of victims so that they cannot escape is kinda counterproductive.

Yes, design professionals can help all of this a lot voluntarily without us making code changes - but the majority of them won't. The whole reason we have codes is to account for human nature. Mass casualty events are rare like fires, so human nature is to save a buck today and gamble that it won't bite you tomorrow.

 

[steveray]

I like this, may not be applicable everywhere, but it is a good start

How can we address egress from multistory schools? My main thing is that I think locking down a room full of victims so that they cannot escape is kinda counterproductive.

Yes, design professionals can help all of this a lot voluntarily without us making code changes - but the majority of them won't. The whole reason we have codes is to account for human nature. Mass casualty events are rare like fires, so human nature is to save a buck today and gamble that it won't bite you tomorrow.

Unless you are up to the lot line, exterior stairs are always an option...

Start making the designers liable for designing death traps...Just like making the gun makers liable......

 

[mtlogcabin]

https://idighardware.com/2022/01/qq-fires-vs-active-shooters-in-schools/

 

[e hilton]

Not to get political … my wife retired from working in the front office of a high school. The administration constantly tells teachers to keep all exit door closed and locked (from the outside). There is always at least one teacher who won’t comply, in her case it was the jr rotc dude. And of course kids put rocks in the door so they can let their friends in who are late from lunch. Her school had a “security guard”, a fat lazy woman, school district employee, who sat in her office all day and did not make the required exterior rounds.

 

[brokenkeys]

Not sure how the rest of the country operates but as a school designer in Florida; security is the number one issue parents talk about at community meetings and CPTED certification has essentially been a minimum requirement to win projects for at least 5 years. School police are also part of the review process in many districts.

The private/ charter side has less restrictions/ requirements, but ownership/ parents still have the same concerns, so we carry over the same concepts from the public side, with the benefit of the private/ charter folks typically having better budgets (Florida public school budgets are limited by State law).

There is no one answer to this issue. Each shooting is different hence CPTED's Onion theory (although I've been hearing it called the Swiss cheese model in relation to covid) of overlapping layers of security; in an attempt to reduce the damage from the inevitable unlocked door, sleeping security guard, etc.

I don't see a benefit to shortening travel distances. Most schools here in Florida are multi-story and snake around the site due to various requirements (travel distance, window requirements, etc.). Making travel distances shorter means more exit doors to observe and control and more courtyards/ challenging spaces to observe and control. While major events like Ulvade grab all the headlines, there are non-headline grabbing events (student violence, parent violence, suicides, etc.) that happen more often and could be made worse if also not considered.

 

[tmurray]

I like this, may not be applicable everywhere, but it is a good start.

How can we address egress from multistory schools? My main thing is that I think locking down a room full of victims so that they cannot escape is kinda counterproductive.

Yes, design professionals can help all of this a lot voluntarily without us making code changes - but the majority of them won't. The whole reason we have codes is to account for human nature. Mass casualty events are rare like fires, so human nature is to save a buck today and gamble that it won't bite you tomorrow.

In addition to being a building official, I also have a certificate as an Active Shooter and Hostile Response Program Specialist from the NFPA (great course if you ever get a chance to take it).

The challenge in dealing with this type of event is the delay in relaying actionable intelligence to building occupants and preventing the hostile agent from intercepting this information. Obviously, armed with advance knowledge of tactics could drastically increase a hostile agents ability to do harm, which makes operational security so important. Most civilian targets deal with the challenges related to relaying actionable intelligence by "hardening" softer civilian targets. This makes entry more challenging, slowing the hostile agent and providing additional response time for an armed response.

The main issue is that the size of most schools and construction make determining the direction of a gunshot challenging. There are many reports of people running towards a shooter thinking that they are running away from one due to the echo of the gunshots.

Where is the hostile agent now?
Where are they moving towards?
Are they shooting everyone, or are they targeting specific people/groups?
What type of weapons do they have?
Do they have high capacity magazines?
How safe is the area you are in?
How unsafe is it to move to a different safe area?

Ultimately, they are attempting to address these types of situations with a broad policy, but it cannot possibly account for all the variables involved. It's also likely an unreasonable assumption to assume most people would be able to look at all the variables and come to a good decision given the stress they are under during the event. A likely exception being former military (particularly combat vets) and a large portion of emergency services.

 

[George Barnes]

Would anyone be interested in drafting or helping to draft code change(s) to egress requirements for schools to help address active shooter scenarios?

I hadn't really thought much about this aspect before, but obviously the topic in general has been a hot one this week.

Currently, the FBI recommended Run Hide Fight tactic is the training that basically everyone receives when it comes to active shooter scenarios. I included it in the PDF here. I'm not going to debate if that is the most effective tactic, but that is the training everyone has.

The first and most survivable tactic, "Run" means to completely escape the area where the shooter is or will be. This is great in a mall, or even many churches, because you have egress paths that get you outside quickly and you can get clear of the area. The problem with that is that the egress path for many classrooms includes corridors, common paths of travel, exit access passageways, and generally funneling people who are egressing down an egress path. The shooter expects people to try to escape, so they block the means of egress. This is somewhat exacerbated by the extra "bonuses" you get by installing sprinkler systems - you figure they will keep the fire knocked down for longer, and give you more time to egress, so you can give a little on egress issues. However, fire is not the only issue to consider.

So then, the victims are left trapped and barricaded into their classrooms, (Hiding), and then Fighting when that doesn't work. Odds are much worse at this point, especially if no one has equivalent weapons to the terrorist(s). If someone with an equivalent weapon is there, everyone else still needs to escape and get out of their way, so the same issues apply.

I am wanting to kick around ideas to maybe shorten travel distances in E occupancies, maybe require EEROs in more classrooms, etc. Like a rabbit warren approach, if the predator comes in one hole, you can just retreat out of another. Obviously, they should be guarded against becoming an entrance for the terrorist to utilize.

I believe that the North American Fire Marshals Association has a workgroup on this subject that may worth review. Also, there have been discussions from designers about expanding the concept of egress through adjoining rooms to allow students to escape such situations by traveling classroom to classroom to avoid having to enter the corridor where an active shooter may be present. One proposed limitation was to only allow travel through two adjacent classrooms and then require a door to the exterior.

 

[Beniah Naylor]

This is my first stab at a potential new code section for the IBC.

1006.2.2.7 – Classrooms in E occupancies. Classrooms in E occupancies, having an occupant load of more than 10 persons, shall have access to not less than two exits or exit access doorways for redundancy in the event of an active shooter/hostile environment situation.

This section is written to closely align with the 2018 IBC 1006.2.2.4 Group I-4 means of egress. The only difference is that I am trying to apply it to classrooms, and that the line is added at the end explaining that is is for an ASHE event. This section was removed in the 2021 IBC, because it was already specified for I-4 occupancies in table 1006.2.1 - see video of the Committee Action Hearings E16-18, and E16-18 (CONTINUATION).

The term "active shooter/hostile environment" comes from NFPA 3000, so I used it here instead of making up a new term.

If anyone has better language, notices problems this causes in other sections, consistency issues, or disagrees entirely, please post it here - I appreciate all feedback, negative or otherwise.

 

[steveray]

How are you going to reconcile it with egress through intervening spaces? as the classrooms will not be accessory to one another ? Which way will the door swing? Now that it is a second required MOE exit and emergency lights/ signs required......Imagine if I had more than a minute.....

 

[Beniah Naylor]

You are referring to 1016.2, number 2? - Egress from a room or space shall not pass through adjoining or intervening rooms or areas, except where such adjoining rooms or areas and the area served are accessory to one or the other, are not a Group H occupancy and provide a discernible path of egress travel to an exit.
Exception: Means of egress are not prohibited through adjoining or intervening rooms or spaces in a Group H, S or F occupancy where the adjoining or intervening rooms or spaces are the same or a lesser hazard occupancy group.

 

[Mr. Inspector]

If we made our schools harder for a shooter to get in wouldn’t they just go to a different building that’s easier to get into like a church or store?

 

[Beniah Naylor]

So, if classroom A has a door to the exterior of the building and a door that opens into the corridor, and classroom B has a door to classroom A and a door to the corridor.

If you are exiting from classroom B, can classroom A be considered an "exit" instead of an "exit access"? Or is the "exit" in this scenario just the exterior door?

 

[steveray]

You are referring to 1016.2, number 2? - Egress from a room or space shall not pass through adjoining or intervening rooms or areas, except where such adjoining rooms or areas and the area served are accessory to one or the other, are not a Group H occupancy and provide a discernible path of egress travel to an exit.
Exception: Means of egress are not prohibited through adjoining or intervening rooms or spaces in a Group H, S or F occupancy where the adjoining or intervening rooms or spaces are the same or a lesser hazard occupancy group.

yes

 

[steveray]

So, if classroom A has a door to the exterior of the building and a door that opens into the corridor, and classroom B has a door to classroom A and a door to the corridor.

If you are exiting from classroom B, can classroom A be considered an "exit" instead of an "exit access"? Or is the "exit" in this scenario just the exterior door?

A classroom can not be an exit...the exterior door can....but you would be egressing through the intervening classroom...

 

[brokenkeys]

So instead of one classroom full of dead kids there would be two?

Robb Elementary, for instance, had numerous smaller tragedies, which combined to a major tragedy. Free egress between two classrooms was one of them:

At 11:27am a teacher propped open a rarely used side door. At 11:28am Mr. Ramos crashed his truck nearby, shooting at a funeral home, cars, nearby pedestrians, etc. then jumped a fence and entered the school at 11:33am. Officers enter the corridor outside the classroom at 11:37, essentially trapping him and cutting him off from the remainder of the school. Then, for over an hour, until border patrol's tactical group makes entry at 12:50, Mr. Ramos is able to freely egress between two classrooms. There was no resource officer on campus, the incident commander had poor communications, a poor understanding of the situation and poor control, which lead to poor decisions. Until border patrol eventually decided, on their own, to end it.

 

[Beniah Naylor]

1006.2.2.7 – Classrooms in E occupancies. Classrooms in E occupancies, having an occupant load of more than 10 persons, shall have access to not less than two exits or exit access doorways for redundancy in the event of an active shooter/hostile environment situation.

So, with this potential code section standing by itself, each classroom would have an exit and an exit access, or two exit accesses. So, you could not exit through adjacent classrooms, but you don't absolutely have to exit directly to the outdoors if you have a compliant exit access. This can be done in many configurations, including multi-story and unlimited area buildings.

I like this as it is, because I think this gives you options to egress when you hear gunshots or see the shooter - you always have somewhere to run.

I also don't have a huge issue with allowing egress through a door into an adjacent room that has an exit to the exterior. Maybe I can submit a separate code change that adds classrooms to the exception in 1016.2, number 2. It's not as good, but it is cheaper and might make things more likely to get accepted.

 

[steveray]

That just gets you 2 doors in the same hall....But if it helps you sleep at night....

 

[ICE]

The discussion is a step in the right direction. A solution is illusive. Obviously I do not have the answer.

More exits requires greater diligence. A recent report on FOX News had a lady who's occupation is teaching school personnel how to prepare and respond to terrorists. She stated that in the years that she has been doing this work she has never not found unlocked doors at the schools that invited her. Those were schools with motivated individuals. So perhaps adding more doors is just not sound.

It has been mentioned that a master door lock activated from an office in an event might be worthy. A locked door is beneficial but only if it is locked by the room occupants. Perhaps an electric lock activated by the fob hanging from a teacher's neck. A school wide alarm that's deafening would be the clue to lock the door. That deafening alarm could be activated by another fob that's available to every teacher and push pads like fire alarms in the hallways. There could be alarm pads similar to rape alarms in the parking lots.

As it is there are thousands of existing schools. The expense and logistics of retrofitting them might be insurmountable. One expensive, yet practical, avenue is security. Think of the local courthouse, airport, some hospitals. There are multiple Police and Deputies to get past.....not some lazy, fat lady. Keep the crazy people and their weapons out....because once they are in, deaths are inevitable.

 

[Beniah Naylor]

That just gets you 2 doors in the same hall....But if it helps you sleep at night....

Fair point. The wording in blue is the changes I made to the original draft.

1006.2.2.7 – Classrooms in E occupancies. Classrooms in E occupancies, having an occupant load of more than 10 persons, shall have access to not less than two independent exits or exit accesses, which shall be arranged so that if one becomes blocked, the other will be available.

...and shall be arranged so that if one becomes blocked, the other will be available. - I stole this wording from 1007.1.2 Three or more exits or exit access doorways. I changed the word "and" to "which" to indicate that the exit or exit access had to be arranged for redundancy, not just the door out of the classroom.

 

[brokenkeys]

I can add second exits on the first floor (K and under classrooms are required to have second exits anyway). But for multi-story schools in Florida, meeting this and all the other requirements would be a serious burden; classrooms are required to have exterior windows, there is a percentage limit for circulation space (variances are possible) and we are prohibited from using exit passageways.