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Exit stair, or exit discharge?

Yankee Chronicler

Registered User
Joined
Oct 17, 2023
Messages
1,261
Location
New England
This question relates to an existing building, but it involves two new stairs so I think this is the appropriate place to ask the question.

The building was constricted in 1883 -- 140 years ago. Old New England type mill building, now being repurposed and split up into multiple, small and medium-size tenant spaces. The current permit application calls for joining a space on the first floor to a space on the second floor (but not directly above the first floor space). This will mean constructing a new open interior stair, meaning that it's a communicating stair and potentially exit access, but it is not an exit stair.

This new stair leads to an exterior door at the first floor level, which is still half a story above grade, and then down a new exterior stair to grade. Constructing the new interior stair will remove a secondary exit from an adjacent occupancy, so the architect is removing a window and making that opening into a new exit door, which will also then lead to an exterior stair to grade.

In the elevation, the two stairs are circled. The one on the right is from the new interior stair, and will serve a space on the second floor. The one on the left is a new exit that will serve a space on the first floor. The architect has called for bricking up basement windows directly beneath the stair landings, but has NOT called for protecting other openings that are within 10 feet of the stairs.

What are the stairs: "exterior exit stairs," or "exit discharge stairs"? (Or both?) What I'm wrestling with is whether or not I need to call for other window openings to be protected.

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The applicable code section is IBC 1027.6:

1027.6 Exterior exit stairway and ramp protection. Exterior
exit stairways and ramps shall be separated from the interior of
the building as required in Section 1023.2. Openings shall be
limited to those necessary for egress from normally occupied
spaces. Where a vertical plane projecting from the edge of an
exterior exit stairway or ramp and landings is exposed by other
parts of the building at an angle of less than 180 degrees (3.14
rad), the exterior wall shall be rated in accordance with Section
1023.7.

Exceptions:
1. Separation from the interior of the building is not
required for occupancies, other than those in Group
R-1 or R-2, in buildings that are not more than two
stories above grade plane where a level of exit discharge
serving such occupancies is the first story
above grade plane.
2. Separation from the interior of the building is not
required where the exterior exit stairway or ramp is
served by an exterior exit ramp or balcony that connects
two remote exterior exit stairways or other
approved exits with a perimeter that is not less than
50 percent open. To be considered open, the opening
shall be not less than 50 percent of the height of
the enclosing wall, with the top of the openings not
less than 7 feet (2134 mm) above the top of the balcony.

There are two more exceptions, but they don't apply to this building so I omitted them to save space. #2 also doesn't apply, so I'm really left with the code section and Exception #1. The first floor is a story above grade, so the building is three stories above grade plus a full-height basement. To the left of the the two new stairs you can see that the main entrance and a major exit are at an intermediate level between the basement floor elevation and the first story floor elevation.

I'm inclined to read the definition of "exterior exit stairway" as applying whether the interior stair is an open exit access stair or an enclosed exit stair. The definition of "exit access stairway" seems to encompass exterior stairs whether they are "exit" stairs" or "exit discharge" stairs. If that's correct, then I believe several more windows need to be bricked up or otherwise protected.

Opinions, please?
 
I am sure the story these stairs serve is considered a "story above grade plane." However, is it the first story above the grade plane?

Where is the grade plane, and what is the elevation of that story?

Is the difference more than 6 feet?

If the answer to that last question is yes, the story is considered a second story, and the stairs would be considered exterior exit stairways. Since the building is more than two stories, the walls must have the required exterior protection, even though the stairs only serve that one story.

If the answer is no, then they are not exterior exit stairways since they serve the first story (level of exit discharge), and the stairs are part of the exit discharge, much like the stairway at what appears to be a main entrance in the center, even though it has fewer steps.
 
We went over this question in the office today, and the boss and another of the ABOs both agree that additional windows flanking the new stairs need to be protected openings.
 
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