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emergency escape and garage

Resubmit the plans and label the garage storage, see what that does to his mind.

Unless the city requires a garage
 
I've reread and rethought this thread, and see now where T-Bird is coming from.

I had to think about the fact that the garage is truly a part of that basement. The requirement for the EERO's does not say where in the basement, just that it has to be in the basement.

If there were no partition walls in that basement, and the required separation was via the ceiling and egress stair, then where is the EERO?? In the garage.

If you had a den, a sewing room, and an office in a basement........the required EERO could be in any of them, or perhaps in a living room, so the intervening room argument does not fly, regardless of the fact that it does not say that in that section.

I did submit this to ICC for an opinion, see what they come back with.
 
fatboy said:
I've reread and rethought this thread, and see now where T-Bird is coming from.

I had to think about the fact that the garage is truly a part of that basement. The requirement for the EERO's does not say where in the basement, just that it has to be in the basement.

If there were no partition walls in that basement, and the required separation was via the ceiling and egress stair, then where is the EERO?? In the garage.

If you had a den, a sewing room, and an office in a basement........the required EERO could be in any of them, or perhaps in a living room, so the intervening room argument does not fly, regardless of the fact that it does not say that in that section.

I did submit this to ICC for an opinion, see what they come back with.
Click to expand...


Yea

A convert

Two more and I get a toaster
 
fatboy said:
I've reread and rethought this thread, and see now where T-Bird is coming from.

I had to think about the fact that the garage is truly a part of that basement. The requirement for the EERO's does not say where in the basement, just that it has to be in the basement.

If there were no partition walls in that basement, and the required separation was via the ceiling and egress stair, then where is the EERO?? In the garage.

If you had a den, a sewing room, and an office in a basement........the required EERO could be in any of them, or perhaps in a living room, so the intervening room argument does not fly, regardless of the fact that it does not say that in that section.

I did submit this to ICC for an opinion, see what they come back with.
Click to expand...


I'm curious to see what they have to say.

I can almost get on board with you; but I'm still seeing a basement and a garage as 2 separate, or independent, things.
 
So, they simplified my question hugely, I had laid out the exact situation and was neutral in my request, but here is the response from ICC;

Following is the response to your question.

October 10, 2017

RE: 15 IRC R310.3

Q1: Can an overhead garage door serve as the emergency escape and rescue opening from a basement garage?

A1: No, Section R310.3 permits doors that are used as emergency escape and rescue openings to be side-hinged or sliders. It does not permit overhead doors to serve as emergency escape and rescue openings.

Copyright © 2017 International Code Council, Inc. All rights reserved.

Code opinions issued by ICC staff are based on ICC-published codes and do not include local, state or federal codes, policies or amendments. This opinion is based on the information which you have provided. We have made no independent effort to verify the accuracy of this information nor have we conducted a review beyond the scope of your question. This opinion does not imply approval of an equivalency, specific product, specific design, or specific installation and cannot be published in any form implying such approval by the International Code Council. As this opinion is only advisory, the final decision is the responsibility of the designated authority charged with the administration and enforcement of this code.



They did not get into the weeds of it being a garage, so I would take from this that if there were a compliant window installed, as the OP suggested earlier, then it should be allowed. I can live with that.
 
Yeah, I sent them the PDF plan that the OP posted, and the entire scenario. I wish I would have saved the question, I thought they usually quote the question in the response.
 
How irritating is that? Changing the question so it is really easy to answer, but basically useless.
 
Yes I am the one doing the review on T-Birds project. I did get a different response back from ICC. Here is the response


R: Section R310.1 of the 2015 International Residential Code


Q. Can the emergency escape and rescue opening serving a basement be located in a garage?


A. No. Where an emergency escape and rescue opening is required, Section R310.1 literally requires access directly into a public way or to a yard or court directly from the basement area. While not expressly indicated, the code never intended for occupants to traverse through a garage to access an emergency escape and rescue opening.


While adequate egress from the basement is provided via the unenclosed stair, this does not negate the requirement for an emergency escape and rescue opening for the basement. Admittedly, based on the submitted sketch, the basement is essentially a mechanical, storage space bounded on three sides by a crawl space. As such, while it may be unlikely that the basement area could be converted to a sleeping area, an emergency escape and rescue opening is literally required unless alternatively approved by the code official.


Code opinions issued by ICC staff are based on ICC-published codes and do not include local, state or federal codes, policies or amendments. This opinion is based on the information which you have provided. We have made no independent effort to verify the accuracy of this information nor have we conducted a review beyond the scope of your question. This opinion does not imply approval of an equivalency, specific product, specific design, or specific installation and cannot be published in any form implying such approval by the International Code Council. As this opinion is only advisory, the final decision is the responsibility of the designated authority charged with the administration and enforcement of this code.


“Copyright © 2017 International Code Council, Inc. All rights reserved.”

I am not going to allow T-Bird to use the EERO in the garage. I had another project like this last year same as T-Birds except in addition to the mechanical room and storage, they has a 316 square foot theater room also a 290 square foot multi purpose room. Where do you draw the line as the basements keep getting bigger trying to use the garage for the EERO.

Here is my determination on the matter


The garage is accessory use to the dwelling unit. The garage can also be part of the basement. However, there is a required fire separation from the garage to the dwelling unit. This separation is to protect the occupants of the dwelling unit from the hazards associated with garages. The garage has an inherent risk factor due to the occupancy classification. To allow egress access through the garage would increase the risk factors for the residence of the dwelling unit trying to exit. The intent of the code is not to increase risk factors but to reduce risk factors for occupants of the dwelling unit
 
Sol said:
Yes I am the one doing the review on T-Birds project. I did get a different response back from ICC. Here is the response


R: Section R310.1 of the 2015 International Residential Code


Q. Can the emergency escape and rescue opening serving a basement be located in a garage?


A. No. Where an emergency escape and rescue opening is required, Section R310.1 literally requires access directly into a public way or to a yard or court directly from the basement area. While not expressly indicated, the code never intended for occupants to traverse through a garage to access an emergency escape and rescue opening.


While adequate egress from the basement is provided via the unenclosed stair, this does not negate the requirement for an emergency escape and rescue opening for the basement. Admittedly, based on the submitted sketch, the basement is essentially a mechanical, storage space bounded on three sides by a crawl space. As such, while it may be unlikely that the basement area could be converted to a sleeping area, an emergency escape and rescue opening is literally required unless alternatively approved by the code official.


Code opinions issued by ICC staff are based on ICC-published codes and do not include local, state or federal codes, policies or amendments. This opinion is based on the information which you have provided. We have made no independent effort to verify the accuracy of this information nor have we conducted a review beyond the scope of your question. This opinion does not imply approval of an equivalency, specific product, specific design, or specific installation and cannot be published in any form implying such approval by the International Code Council. As this opinion is only advisory, the final decision is the responsibility of the designated authority charged with the administration and enforcement of this code.


“Copyright © 2017 International Code Council, Inc. All rights reserved.”

I am not going to allow T-Bird to use the EERO in the garage. I had another project like this last year same as T-Birds except in addition to the mechanical room and storage, they has a 316 square foot theater room also a 290 square foot multi purpose room. Where do you draw the line as the basements keep getting bigger trying to use the garage for the EERO.

Here is my determination on the matter


The garage is accessory use to the dwelling unit. The garage can also be part of the basement. However, there is a required fire separation from the garage to the dwelling unit. This separation is to protect the occupants of the dwelling unit from the hazards associated with garages. The garage has an inherent risk factor due to the occupancy classification. To allow egress access through the garage would increase the risk factors for the residence of the dwelling unit trying to exit. The intent of the code is not to increase risk factors but to reduce risk factors for occupants of the dwelling unit
Click to expand...


So if the basement only contained the garage than what ??

With the eero?

Plus, it would only be used if the stairs were blocked.
 
Sol, I for one thank you for posting your thoughts here. Your opinion is certainly well reasoned and defensible. At the end of the day, however, I disagree, keeping in mind that I am an architect and not a code official so my perspective differs.

The statement by the ICC that "the code never intended for occupants to traverse through a garage to access an emergency escape and rescue opening" doesn't really help. How are we supposed to figure that out? All we can go on is what is actually written in the code. If the code really didn't intend for occupants to traverse through a garage for an EERO then it would include similar language that prohibits such access to means of egress. But the code does not include that language in the EERO paragraph.

From my point of view, an EERO access from a basement through a garage certainly provides safety. If there is a fire in the garage there is the actual means of egress up the stairs and out the door; if there is a fire that blocks that means of egress there is the EERO through the garage. I honestly don't understand how that is not a benefit. The code clearly requires both a means of egress and an EERO and your points about future potential uses of the basement are completely reasonable, I suspect that is why the EERO requirement for basements was added to the code. So, I agree that you are completely correct to insist on an EERO in the basement, but if there is not an actual sleeping room I still don't see how the currently written code denies access to that EERO through any part of the basement, even if it is through a garage or other similarly hazardous area. It is after all a means of escape, not an exit. If that is truly the intent of the code it needs to be clarified in the code.
 
cda said:
So if the basement only contained the garage than what ??

With the eero?

Plus, it would only be used if the stairs were blocked.
Click to expand...
Allow me to rephrase:
A detached garage having the parking level a story below grade requires an EERO?
What's the difference if it's attached below the dwelling unit?
When the 2006 IRC deleted "with habitable space" and added the exception for mechanical rooms not exceeding 200 sf. was intended to include (Group U) accessory structures; attached or detached?

Granted search "Garage EERO" and you will find a couple states that allow an EERO through the basement garage; but to my knowledge where issued before this code change or for unique conditions such as hurricane prone areas and is therefore only applicable to those states or localities.
 
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Sounds like this is case by case,, ahj by ahj to decide.


I still cannot believe this is the first time a design like this has come up.
 
Me

If no give on using the garage,

I would find some way to put the EERO directly next to the exit stairs,,,

And see if the ahj says anything
 
Sleepy said:
Sol, I for one thank you for posting your thoughts here. Your opinion is certainly well reasoned and defensible. At the end of the day, however, I disagree, keeping in mind that I am an architect and not a code official so my perspective differs.

The statement by the ICC that "the code never intended for occupants to traverse through a garage to access an emergency escape and rescue opening" doesn't really help. How are we supposed to figure that out? All we can go on is what is actually written in the code. If the code really didn't intend for occupants to traverse through a garage for an EERO then it would include similar language that prohibits such access to means of egress. But the code does not include that language in the EERO paragraph.

From my point of view, an EERO access from a basement through a garage certainly provides safety. If there is a fire in the garage there is the actual means of egress up the stairs and out the door; if there is a fire that blocks that means of egress there is the EERO through the garage. I honestly don't understand how that is not a benefit. The code clearly requires both a means of egress and an EERO and your points about future potential uses of the basement are completely reasonable, I suspect that is why the EERO requirement for basements was added to the code. So, I agree that you are completely correct to insist on an EERO in the basement, but if there is not an actual sleeping room I still don't see how the currently written code denies access to that EERO through any part of the basement, even if it is through a garage or other similarly hazardous area. It is after all a means of escape, not an exit. If that is truly the intent of the code it needs to be clarified in the code.
Click to expand...
Completely agree with you. As a building official, I cannot enforce the "intent" of the code. I can only enforce the code. If the code is not intended to address your construction, let's have a discussion about it.

Unless it's arson, both paths should not be inaccessible at the same time. The code is not intended to address intentional fires, only accidental. I'm still struggling to understand why two paths are even required. The interpretation from ICC seems to imply that it is required if one of the rooms in the basement is converted into a sleeping room. Would this not be a change of use and reviewed as part of that permit?
 
tmurray said:
Completely agree with you. As a building official, I cannot enforce the "intent" of the code. I can only enforce the code. If the code is not intended to address your construction, let's have a discussion about it.

Unless it's arson, both paths should not be inaccessible at the same time. The code is not intended to address intentional fires, only accidental. I'm still struggling to understand why two paths are even required. The interpretation from ICC seems to imply that it is required if one of the rooms in the basement is converted into a sleeping room. Would this not be a change of use and reviewed as part of that permit?
Click to expand...



I would say no

If a basement with four walls, no sleeping.

A EERO is still required
 
The AHJ submitted the plans to the ICC and the verdict is in. I still disagree with the conclusion and would love to discuss this directly with them.

R: Section R310.1 of the 2015 International Residential Code

Q. Can the emergency escape and rescue opening serving a basement be located in a garage?

A. No. Where an emergency escape and rescue opening is required, Section R310.1 literally requires access directly into a public way or to a yard or court directly from the basement area. While not expressly indicated, the code never intended for occupants to traverse through a garage to access an emergency escape and rescue opening.


While adequate egress from the basement is provided via the unenclosed stair, this does not negate the requirement for an emergency escape and rescue opening for the basement. Admittedly, based on the submitted sketch, the basement is essentially a mechanical, storage space bounded on three sides by a crawl space. As such, while it may be unlikely that the basement area could be converted to a sleeping area, an emergency escape and rescue opening is literally required unless alternatively approved by the code official.
 
The garage is part of the basement. The so-called "separation" between the garage and rest of the basement is "Not less than 1/2-inch gypsum board or equivalent applied to the garage side" (IRC Table R302.6). This is less than typical interior walls which usually have 1/2" gypsum board on both sides.
 
T-Bird said:
The AHJ submitted the plans to the ICC and the verdict is in. I still disagree with the conclusion and would love to discuss this directly with them.

R: Section R310.1 of the 2015 International Residential Code

Q. Can the emergency escape and rescue opening serving a basement be located in a garage?

A. No. Where an emergency escape and rescue opening is required, Section R310.1 literally requires access directly into a public way or to a yard or court directly from the basement area. While not expressly indicated, the code never intended for occupants to traverse through a garage to access an emergency escape and rescue opening.


While adequate egress from the basement is provided via the unenclosed stair, this does not negate the requirement for an emergency escape and rescue opening for the basement. Admittedly, based on the submitted sketch, the basement is essentially a mechanical, storage space bounded on three sides by a crawl space. As such, while it may be unlikely that the basement area could be converted to a sleeping area, an emergency escape and rescue opening is literally required unless alternatively approved by the code official.
Click to expand...


Love it

Required

You provided it

Still not good
 
fatboy said:
I wish I would have saved the question, I thought they usually quote the question in the response.
Click to expand...

Correct, this is usually how they start;
In your recent online submission, you ask the following question, as stated in my own words, with my response immediately following:
 
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