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"I did not know I needed a permit" he said

I have been instructed to use the green book with any older code issues from the regional contact engineer here on Long Island NY. Home I was addressing was built in 1934 and they have a finished attic space original with the house when built. They are Remodelling the space......insulating, new finishes and windows etc. and someone may sleep there. Just concerned since windows don't meet today's egress sizes and they are proposing direct size replacement windows. No back stair or anything or even lower intermediate roof to climb down to with a rope ladder. Code in effect in 1935 I believe allowed sleeping rooms in attic space. What do you think
 
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Egress Windows are not just for you getting out
EgressWindows.jpg
 
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This could be seen as maintenance only work?
Existing window size is a "risk management issue"
If current code has ne retroactive requirement to "cure" existing non-conforming conditions then maintaining window size is at the owners risk to do so, or not.
 
Replacement of Glass is maintenance
Replacement of window is NOT maintenance

2016 CALIFORNIA EXISTING BUILDING CODE
105.2.2
"...change of any required means of egress or rearrangement of parts of a structure affecting the egress requirements"
2016 CRC 1.1.3 Scope. The provisions of this code shall apply to the construction, alteration, movement, enlargement, replacement,......
2016 CRC R101.2 Scope. The provisions of the California Residential Code for One- and Two-family Dwellings shall apply to the construction, alteration, movement, enlargement, replacement,....

NOT ADDOPTED BY STATE PER MATRIX ADOPTION TABLE
2016 CALIFORNIA EXISTING BUILDING CODE 406.3 Replacement window emergency escape and rescue openings. Where windows are required to provide emergency escape and rescue openings in Group R-2 and R-3 occupancies, replacement windows shall be exempt from the requirements of Sections 1030.2, 1030.3 and 1030.5 provided the replacement window meets the following conditions:
1. The replacement window is the manufacturer’s largest standard size window that will fit within the existing frame or existing rough opening. The replacement window shall be permitted to be of the same operating style as the existing window or a style that provides for an equal or greater window opening area than the existing window.
2. The replacement of the window is not part of a change of occupancy.
 
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