Existing back alleyway less than 44" - can it qualify as one of the exits/exit discharge? (California)

[e hilton]

If there is a door that leads from inside the building to the outside … pray tell what purpose does it serve other than egress? Decoration?

 

[classicT]

If there is a door that leads from inside the building to the outside … pray tell what purpose does it serve other than egress? Decoration?

First off, I get your point and agree... but no, not all exterior doors are intended for egress.

Case in point, the door pictured below is most likely (not my picture) for access to replace mechanical equipment or facilitate some other process.

 

[bill1952]

If there is a door that leads from inside the building to the outside … pray tell what purpose does it serve other than egress? Decoration?

I did offer some examples above, even though I asked very similar question in other thread.

 

[bill1952]

But if you don’t mark the door with a lighted exit sign, or any signs … seems like you would not need full compliance.

Certainly seems you were on other side before.

 

[bill1952]

And more supporting the door does'nt have to comply if not intended for egress:

If you have a space that requires 2 exit doors but has 12 exit doors, then only 2 doors need to be made "code compliant" with the provisions IBC chapter 10 'Means Of Egress'. You certainly would not have exit signs on the other 10 doors if you don't intend to use them for exiting.

If the door is required to be an exit for some reason under the code, it must meet all the requirements for an exit door.
If the door is signed as an exit, even if it is not required by code, it has to function like an exit (occupants cannot be expected to spot a "fake" signed exit).
If it is what most people call a convenience door and is not signed as an exit, I don't care what you do with it, provided it does not violate other code provisions.

TM has the best synopsis.....No AHJ should be making you do what the code does not.

 

[e hilton]

Certainly seems you were on other side before.

I’m taking lessons from my wife.
More importantly, if someone offers good logic or proof that my way is wrong, i’m not so stubborn that i can't change. .

 

[ICE]

ice - I agree with your point of view, but you leave out an important few words which others use to justify not treating additional as exit doors, namely "Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section."

Again, I agree that these additional doors to exterior should meet the code requirements as if they were provided for egress. I believe in the other thread the consensus was that if someone - owner, architect, tennant, othere - makes the case that they are not "provided for egress purposes" then no requirements comply.

1010.1 Doors. Means of egress doors shall meet the requirements of this section. Doors serving a means of egress system shall meet the requirements of this section and Section 1022.2. Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section.

It does come down to who determines the purpose of a door. The purpose of a door is obvious. To assume that a door that is in addition to the required means of egress door need not meet the requirements of a means of egress door simply because an entity has determined that said door was not provided for egress purposes …. That’s just wrong.

How about the homeowners that tell you that no smoke alarm is required in that bedroom because they are using it as an office. Did that bedroom magically become not a bedroom. Didn’t happen did it. It didn’t happen because there is no reason to rely on the the occupants to respect the designation as an office and not use it as a bedroom. It is after all a bedroom.

Providing doors that do not meet the same requirements as a “means of egress system” doors Is legal as long as it is not possible to “egress“ through the door. Well then, what is the definition of egress through a door? My conclusion is that egressing a space means exiting that space.

I’ll provide an example. A nightclub is required to have four exits. The club has six doors to the exterior. Four of the doors open in the direction of travel and two swing in. All but the blind people see the six doors. The people don’t perform a mental exercise to decide which doors are the required egress doors…you know, much as the architect did. No, not at all. They see the doors….they know that the other side of the door is outside.

Now unfortunately a pyrotechnic display ignites the ceiling. People are fleeing. The people that found the four required exit doors got out. The people that found the extra exit doors that swung in were found later that night.

Buildings will present individual situations. Residential as opposed to commercial, etc. The final arbiter is the occupant that opens the door. An absolute exception applied to doors over and above the required number of doors due to semantics is not just wrong but is also unjustifiable.

 

[bill1952]

ICE - I said early in other thread what you say here, which was a minority opinion. Wish you were as emphatic in that thread as you are in this one.

Count the posters and their views in other thread. Majority feel you it's fine to have a door to exterior which is not required for MOE not comply with code requirements.

If not provided for egress WTF is it intended for? Based on over a 100 projects in nearly as many jurisdictions, I don't recall on building department that would allow a non-compliant door no matter what anyone insisted it was intended for.

 

[ICE]

ICE - I said early in other thread what you say here, which was a minority opinion. Wish you were as emphatic in that thread as you are in this one.

Count the posters and their views in other thread. Majority feel you it's fine to have a door to exterior which is not required for MOE not comply with code requirements.

If not provided for egress WTF is it intended for? Based on over a 100 projects in nearly as many jurisdictions, I don't recall on building department that would allow a non-compliant door no matter what anyone insisted it was intended for.

Done……

 

[my250r11]

If this was a new build every door would absolutely need to be complaint. This is existing and the door that has to narrow a walkway/egress path, I would have it marked as not an exit and the other doors made a complaint as possible. Just my 2 cents but it really comes down to what the local AHJ is willing to accept.

 

[tmurray]

1010.1 Doors. Means of egress doors shall meet the requirements of this section. Doors serving a means of egress system shall meet the requirements of this section and Section 1022.2. Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section.

It does come down to who determines the purpose of a door. The purpose of a door is obvious. To assume that a door that is in addition to the required means of egress door need not meet the requirements of a means of egress door simply because an entity has determined that said door was not provided for egress purposes …. That’s just wrong.

How about the homeowners that tell you that no smoke alarm is required in that bedroom because they are using it as an office. Did that bedroom magically become not a bedroom. Didn’t happen did it. It didn’t happen because there is no reason to rely on the the occupants to respect the designation as an office and not use it as a bedroom. It is after all a bedroom.

Providing doors that do not meet the same requirements as a “means of egress system” doors Is legal as long as it is not possible to “egress“ through the door. Well then, what is the definition of egress through a door? My conclusion is that egressing a space means exiting that space.

I’ll provide an example. A nightclub is required to have four exits. The club has six doors to the exterior. Four of the doors open in the direction of travel and two swing in. All but the blind people see the six doors. The people don’t perform a mental exercise to decide which doors are the required egress doors…you know, much as the architect did. No, not at all. They see the doors….they know that the other side of the door is outside.

Now unfortunately a pyrotechnic display ignites the ceiling. People are fleeing. The people that found the four required exit doors got out. The people that found the extra exit doors that swung in were found later that night.

Buildings will present individual situations. Residential as opposed to commercial, etc. The final arbiter is the occupant that opens the door. An absolute exception applied to doors over and above the required number of doors due to semantics is not just wrong but is also unjustifiable.

The issue I have with the argument that people see a door in an emergency and blindly go through it, is simply false. The numbers change somewhat, but the numbers I've heard thrown around by fire engineers are that about 90% of people try to go back out the door they came in, in an emergency.

So, we are in a building and it catches on fire. Are you going to just try to go through random, unsigned, doors to get out? Oops, this one is an office. And here is a janitors closet. Why are people not just going towards the signed exits?

Did we not do our jobs to make sure there were sufficient exits distributed properly throughout the building during construction/renovation? Did something change in the operation and did fire officials not do their job to ensure that it was being used properly from a commodities level, occupant loading, or compromising the exits? Maybe the codes are wrong and need revised. If people are so desperate to find an exit in an emergency they are picking between door number one, two, or three, surely something else must be wrong.

We've had this discussion already in another thread. The decision to include the wording "provided for egress purposes" cannot be anything but an intentional intention to limit the application of this clause from applying to any door. Re-read the section without those words and that is what you have. A clause that applies to every door regardless of why the designer included the door.

Just to clarify, your interpretation indicates that the base code does not provide sufficient exits, and that the additional doors provided by the designer are necessary to the safe operation of the suite and must be turned into exits. This seems like a very tenuous reliance on the building's conditions to meet life safety requirements for the occupants. Why are we not amending the code to ensure the proper number of exits are installed and located properly? I mean really, these extra doors can be located anywhere, or the designer can simply remove them since they are not required to meet code. Lets codify it and make sure we are meeting life safety requirements.

 

[bill1952]

people try to go back out the door they came in

So if everyone comes in a door that is not provided for egress, swings in, has a complicated lock, and no landing, that's OK?

You mention office doors and janitors closets, but this has generally been about doors to the exterior, in exterior walls, and for the most part having access to the public way.

 

[tmurray]

So if everyone comes in a door that is not provided for egress, swings in, has a complicated lock, and no landing, that's OK?

You mention office doors and janitors closets, but this has generally been about doors to the exterior, in exterior walls, and for the most part having access to the public way.

1. Main entry doors have to be an exit in our code and meet certain capacity requirements for the entire suite (I would presume it is similar in yours). There is a capacity exception for buildings like malls (which entrance is the "main entrance"???).

2. How is the building user to know what doors open to the outside? If there is a window in it or they work there sure they would, but otherwise, they are blindly opening doors hoping that they lead outside because they cannot reach a signed exit.

If this truly is the issue people are making it, the code needs revised. Travel distances to exits needs reduced to require a better distribution of exits throughout the building. If this interpretation is true, we're relying on designers to place doors at the right locations in the interest of public safety and then forcing them to make them exits. How does this make sense?

 

[bill1952]

1. Might not be main entrance, just the one nearest free street parking that employees use, and are familiar with.
2. If the door complied, with hardware, size, landings, swing, signage, etc., it would be easy.

If there are doors in exterior walls providing access to the public way but not provided for egress, what are they provided for? Future tenant build out perhaps, but when built out, they'd probably have to comply and would be provided for egress.

I'd be curious what staff says.

 

[Paul Sweet]

Some doors to public spaces are intended to move furnishings, equipment, exhibits, etc. in and out of the space, and not for egress.

Why not do what ADA requires for non-accessible exits and put a sign on the door saying "Not an exit" with an arrow pointing to the nearest exit?

 

[bill1952]

I'm not sure the compelling reason to not treat "extra" doors to the exterior like required doors. Can't save much money. As far as "not an exit" is that illuminated, in braille, and or in Spanish? Also one near floor for smokey environment? I'll ignore the active shooter in direction of the required and operable egress.

Luckily we can all do as we please to some degree and I'll remain a proponent of treating them like egress doors, because it will ultimately save time and money. Too often told by official that if it can be used as an exit, it will be, and therefore better comply. A change order for one to be made compliant at end of construction will cost more than making 10 or 20 or more compliant in design.

 

[mtlogcabin]

If there are doors in exterior walls providing access to the public way but not provided for egress, what are they provided for?

Not all doors in an exterior wall are for exiting some may be for fire department access
An F-2 or S-2 non sprinklered windowless building for example
2018 IBC
[F] 903.2.11.1 Stories without openings.
An automatic sprinkler system shall be installed throughout all stories, including basements, of all buildings where the floor area exceeds 1,500 square feet (139.4 m2) and where the story does not comply with the following criteria for exterior wall openings:

2. Openings entirely above the adjoining ground level totaling not less than 20 square feet (1.86 m2) in each 50 linear feet (15 240 mm), or fraction thereof, of exterior wall in the story on not fewer than one side. The required openings shall be distributed such that the lineal distance between adjacent openings does not exceed 50 feet (15 240 mm). The height of the bottom of the clear opening shall not exceed 44 inches (1118 mm) measured from the floor.

2018 IFC

SECTION 504
ACCESS TO BUILDING OPENINGS AND ROOFS

504.1 Required access.
Exterior doors and openings required by this code or the International Building Code shall be maintained readily accessible for emergency access by the fire department. An approved access walkway leading from fire apparatus access roads to exterior openings shall be provided where required by the fire code official.

504.2 Maintenance of exterior doors and openings.
Exterior doors and their function shall not be eliminated without prior approval. Exterior doors that have been rendered nonfunctional and that retain a functional door exterior appearance shall have a sign affixed to the exterior side of the door with the words THIS DOOR BLOCKED. The sign shall consist of letters having a principal stroke of not less than 3/4 inch (19.1 mm) wide and not less than 6 inches (152 mm) high on a contrasting background. Required fire department access doors shall not be obstructed or eliminated. Exit and exit access doors shall comply with Chapter 10. Access doors for high-piled combustible storage shall comply with Section 3206.7.

 

[Mr. Inspector]

Many times I see exterior doors to loading docks without a stairway to grade and to fenced in storage areas. I would not make these be a means of egress.

 

[Yikes]

Now unfortunately a pyrotechnic display ignites the ceiling. People are fleeing. The people that found the four required exit doors got out. The people that found the extra exit doors that swung in were found later that night.

Buildings will present individual situations. Residential as opposed to commercial, etc. The final arbiter is the occupant that opens the door. An absolute exception applied to doors over and above the required number of doors due to semantics is not just wrong but is also unjustifiable.

What I find interesting about this is that if this was at a nightclub for 49 occupants and I was the first one to reach the door, the code assumes I would be able to overcome the force of 48 other people pressing in behind me so that I can swing the door inward; but hey, 50 people pressing behind me is just too much to handle.


Yes, in a non- "I" occupancy, the final arbiter of who makes it out alive is the occupant that opens the door. But when it comes to building design for purposes of declaring life-safety, the prescriptive requirements of the building code are the final arbiter of what society deems as meeting the minimum requirements to be called "safe". Yes, I know that sounds callous, but that's how risk management works.

 

[bill1952]

Many times I see exterior doors to loading docks without a stairway to grade and to fenced in storage areas. I would not make these be a means of egress.

Which is why I said with access to the public way.

 

[tmurray]

1. Might not be main entrance, just the one nearest free street parking that employees use, and are familiar with.
2. If the door complied, with hardware, size, landings, swing, signage, etc., it would be easy.

If there are doors in exterior walls providing access to the public way but not provided for egress, what are they provided for? Future tenant build out perhaps, but when built out, they'd probably have to comply and would be provided for egress.

I'd be curious what staff says.

Who cares? Code says what is says. That is what I can enforce. When the code provides clear and concise language like it does here, there is little room for interpretation.

I have neither the ego nor the will to enforce what I think the code should say over what the majority of experts have deemed to be safe design practices, which was then enacted into law by my democratically elected officials, to say nothing of the potential liability exposure.

Besides, if occupants have that concern, the owner and/or designer can install additional exits. It is not the building official's responsibility to satisfy the safety concerns of building occupants.

 

[bill1952]

When the code provides clear and concise language

Really? When your interp is far from a majority opinion? I don't take exception to your other thoughts but the code is anything but "clear and concise" on this.

 

[tmurray]

Really? When your interp is far from a majority opinion? I don't take exception to your other thoughts but the code is anything but "clear and concise" on this.

Using the majority to base your opinion off of is a logical fallacy called appeal to majority. Basically, it is the belief that since the majority of people believe something it must be true. A good example of this is when most people believed the Earth was the center of the solar system. It was not and they were all wrong.

I guess I am just having trouble understanding what is not clear with "provided for egress purposes".

Is it every door? Nope, just those provided for egress purposes.

Is it every door someone could possibly use for egress? Nope, just those provided for egress purposes.

When I can answer plain English questions with the literal wording from the code, it's clear and concise. Belief that it is anything else is likely a function of confirmation bias forcing the individual to believe they are right to either avoid cognitive dissonance or prevent damage to their ego. Maybe both.

I have yet to hear a compelling argument on why the opposing interpretation is correct, other than the concern for people's safety, which is coincidentally another logical fallacy called appeal to emotion. A well considered counter argument would focus on the the emphasis being in a different part of the clause, which may change the meaning. Evidence presented at the code change meeting where this clause was approved. Something tangible and factual about the clause itself. Anything else is just creating an excuse as to why the official is allowed to misinterpret the code to provide them powers outside of what has been lawfully provided to them.

I would agree there are times where it may be necessary to step in and work through a problem with owners and designers where the code does not really address a specific situation. This is not what is happening here.

 

[e hilton]

, other than the concern for people's safety, which is coincidentally another logical fallacy called appeal to emotion.

If codes were not created for peoples safety … then why do they exist? What is the purpose of EERO? Handrails on stairs? GFCI outlets?