Exterior exit access stair: R-2 two story

[chad king]

- 2021 IBC
- 16 unit 2-story R-2 condo with 8 units down / 8 units up (each unit one story)
- 2nd story units: a) either have their on private exterior stair to grade or b) share a exterior stair to grade with one other unit
- common path of travel down to grade is less than 125'

Question: Can I classify these stairs as and exit access stair vs. exterior exit stair which would require stair protection? I have windows less than 10' exposed to the stair less than 180 degrees.

I was thinking if I could classify them as an exit access stair per 1019.3 exception #1 then I wouldn't need stair protection?

 

[Jean Tessmer-HI]

What do you mean by stair protection?
All your ground floor units will need to be fair housing act compliant unless there is an elevator to the top floor then all units need to meet fair housing act.

 

[chad king]

If the stairs are considered exterior exit stairs per section 1027.6 Exterior exit stairway and ramp protection they will require any opening within 10' to be a protected opening. (if it less than 180 degrees)

I was thinking if I could classify the stair as an exit access stair w/ a common path of travel of less than 125' I would have to protect the window that is 3' away at an angle less than 180 degrees

 

[chad king]

oops, meant to say...

I was thinking if I could classify the stair as an exit access stair w/ a common path of travel of less than 125' I would NOT have to protect the window that is 3' away at an angle less than 180 degrees.

 

[chad king]

Anybody else have input?

 

[Mr. Inspector]

Can't do that. A exit access stairway can only be before the exit door not after.

EXIT. That portion of a means of egress system between the
exit access and the exit discharge or public way. Exit components
include exterior exit doors at the level of exit discharge,
interior exit stairways and ramps, exit passageways, exterior
exit stairways and ramps and horizontal exits.
EXIT ACCESS. That portion of a means of egress system
that leads from any occupied portion of a building or structure
to an exit.

EXIT ACCESS STAIRWAY. A stairway with the exit
access portion of the means of egress system.
EXIT DISCHARGE. That portion of a means of egress system
between the termination of an exit and a public way.
EXIT DISCHARGE, LEVEL OF. The story at the point at
which an exit terminates and an exit discharge begins.

 

[chad king]

There is no exit door. You go from exit access to exit discharge.

EXIT ACCESS - You go from the unit to the exit access door (front door of unit) down the access exit stair - all still part of the exit access.

EXIT DISCHARGE -bottom of exit access stair.

 

[Sifu]

No resolution to this question, which I have now encountered, but make it three stories. All units have their own set of exterior stairs. Reading the commentary, an exterior exit stair "typically" involves change in level of less than a story. And, reading further, it says "exit stairways and ramps traverse a full story or more". So what is an "exit stairway"?

 

[Mr. Inspector]

Chad, so what did the plan reviewer for the permit say about it?

 

[chad king]

Hi Rick18071, the reviewer said he agreed that I could apply 2021 IBC 1019.3 exemption 1 as we are only dealing with at two story building and we are meeting the requirements for one exit.

 

[Sifu]

So they moved away from exterior exit stairs, which makes sense, and utilize the provisions of exit access stairways. I think exception #3 to that section hits closest to home if we get away from the literal meaning of "contained within". I could see an argument that until the stair reaches the level of discharge it is contained within the dwelling. However, as the stair goes down it picks up the occupants from the level below. Not sure if the containment argument holds water at that point. We don't have a floor opening in the sense of these provisions, which is charging language for exit access stairs. It seems counter-intuitive to enclose the stair to protect the occupants in an open exterior stair, but if exception #3 isn't applicable that is where the code would take us.

 

[Sifu]

Still conflicted. As Rick says, they aren't exit access stairways by definition. If everything from the inside of the unit to the stairs is exit access, the stairs are the exit, and the termination at the level of exit discharge to the public way is the exit discharge, then the stairs are not part of the exit access. They are an exit, and they are stairs, which equals the (undefined) term exit stairway. Using the exterior exit stairway definition comes closest, even if the commentary indicates they are not used to traverse multiple stories.

 

[steveray]

What is the travel distance off of the second floor? That is typically the driver for a rated enclosure or protected exit that would not fall under exit access.....

 

[Sifu]

The travel distance from the most remote point of the third floor unit following the path of the stairs to the exit discharge is 76', though I'm not sure I follow.

 

[steveray]

If you exceed travel distance, you need a protected exit to make travel distance "stop"....... I don't do a lot of exterior stairs because snow.....But logically if you did not need an exit enclosure you should not need to protect the exterior stairs from the building..i.e. they would still be exit access......

I'd have to see the plans and actually open a book to get into the weeds on it...We still don't allow exit access stairs for >10 OL in CT....FMs have that locked down

 

[Sifu]

I have asked for a code opinion. We too can get feet of snow, maybe get one tomorrow! But I don't have any code sections for logical designs.

 

[Sifu]

I asked for a staff opinion to help me interpret the code. Now I will ask ya'll to help me interpret their answer. Below is exactly what I sent and received. I am wondering if they missed the part I bolded in the first sentence??

Considering two R2 buildings, two and three stories. All units have direct access to a public way via an exterior stair. Occupants from above traverse down, picking up the occupants from the story below until arriving at the public way at the bottom of the stairs. How do these stairs get treated? Are they exit access stairs? Or are they exterior exit stairs? Or something else ("exit stairways" per the commentary) 2018 commentary indicates exterior exit stairs are "typically" not used to traverse from one story to another, and the stair would appear to be the exit, not part of the exit access. But if they were considered an exit access stair, the stairs are not contained within the unit as required by exc. #3. Attached is an example of a two-story unit, but three story are also proposed.



ANSWER: Based on the provisions of Sections 1006.3.1 and 1017.3.1, it is clearly evident that the code permits occupants to use an exit access stairway in order to gain access to a required exit on the adjacent story (e.g., second story down to first story). As such, for the proposed two-story condition depicted in the provided partial building elevation, the outdoor stairway may be reviewed as a vertical component of the path of egress travel to the exit located on the adjacent level (i.e., first floor, which is the level of exit discharge). As such, the proposed two-story stairway is not required to be reviewed in accordance with Section 1027.1 because the stairway is not required to be an exit stairway. (Note: since it appears that the proposed design may be a single exit Group R-2 building, the maximum travel distance limitation would be required to be measured to the bottom of the stairway.) By contrast, the other suggested design involving a third story condition would require that the third story occupants travel more than one adjacent story in order to access the exit located on the level of exit discharge and, therefore, would not comply with Section 1006.3.1.

 

[steveray]

By contrast, the other suggested design involving a third story condition would require that the third story occupants travel more than one adjacent story in order to access the exit located on the level of exit discharge and, therefore, would not comply with Section 1006.3.1.

I think that is their point.....?