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Egress thru Intervening Space - toilet room lobby?

Fast_Edd1e

REGISTERED
Joined
Jun 30, 2021
Messages
36
Location
Michigan
Michigan building code 2015

I have a bank we are designing. There is the main bank area. Then a arched opening to a "back of house" area where the toilet rooms, mechanical and break room are located. Only one means of egress is required for the occupant load and travel distance. The exit door in the break room is just employee convienence.

The owner wants to place a passage door separating the bank from the toilet rooms. This would not be locked. However i feel this triggers the "egress through an intervening space" since to exit the toilet room, you then have to pass thru another door to see an exit.

But Im questioning if it would trigger this because these spaces are "accessory" to the bank.

"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."

What are people opinion on this?

Sketch.jpg
 
You do not show this door on your sketch but it sounds like you are creating a vestibule to the bathroom area which is perfectly acceptable.
 
You do not show this door on your sketch but it sounds like you are creating a vestibule to the bathroom area which is perfectly acceptable.
Correct. They would like to provide a door at that location. Creating a vestibule. All the spaces are either data, storage, mechanical or toilet rooms. The break room would have direct egress.
 
Looks to me like adding a door would create an intervening room (in yellow below) that is a type of lobby, which is an accessory to all the other spaces: the restroom and the break room and the mechanical room. Yes, I would allow it.

1724367586055.png

1016.2 Egress Through Intervening Spaces​

Diagram
Egress through intervening spaces shall comply with this section.
  1. Exit access through an enclosed elevator lobby is permitted. Access to not less than one of the required exits shall be provided without travel through the enclosed elevator lobbies required by Section 3006. Where the path of exit access travel passes through an enclosed elevator lobby, the level of protection required for the enclosed elevator lobby is not required to be extended to the exit unless direct access to an exit is required by other sections of this code.
  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.
 
Be careful -- it's a trap.

Banks don't like to allow customers to use the toilet rooms, that's why they always (almost) want to hide the toilet rooms behind a door. Then they want to lock the door so only employees can access the toilet rooms. However, the IBC and the IPC require that toilet rooms in banks be available to patrons. If you allow the door, make certain it can't be locked and that there is toilet room signage on the lobby side.
 
Be careful -- it's a trap.

Banks don't like to allow customers to use the toilet rooms, that's why they always (almost) want to hide the toilet rooms behind a door. Then they want to lock the door so only employees can access the toilet rooms. However, the IBC and the IPC require that toilet rooms in banks be available to patrons. If you allow the door, make certain it can't be locked and that there is toilet room signage on the lobby side.

Are you referring to this? (“Readily seen” = another subjective interpretation!)

IMG_4965.jpeg
 
Are you referring to this? (“Readily seen” = another subjective interpretation!)

No. I'm referring to the tendency of banks (and CVS pharmacies) to hide the only toilet rooms behind locked doors in order to make them inaccessible to patrons. I have lost count of how many banks I have had this argument with.

Often, the route to the toilet room(s) is behind the teller counter, and (naturally) customers are not allowed behind the teller counter. When I point out that the toilet room(s) is/are required to be available to patrons, the response is "But we can't allow customers behind the teller counter."

And then I ask, "The why did your architect put the toilet room(s) behind the teller counter?"

The answer, of course, (which they won't admit to) is that it's because the bank told the architect to put the toilet room(s) back there, because they don't want customers to use their toilet rooms.

1724426883246.png

Sometimes they try to argue that a bank falls under Exception #2, for quick transactions. Then I ask if their branches let customers open new accounts, apply for mortgages, and if they offer brokerage consulting services. Of course they do -- and none of that falls within the quick pick-up and drop-off exception.
 
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