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I have a client that has been operating an escape room games in a tenant space in the City of Tualatin, Oregon without permits. The space is 4,300 s.f. and unsprinkled. I'm tasked with creating a life safety plan with any required upgrades. This is the City's first time dealing with an escape room. I asked a senior inspector the following questions about the City's position on locking players in rooms:
Question #1 - "Door Locks: I am still not sure how to address the door hardware issues for the escape rooms. You said you would discuss this with your colleagues and let us know. I don’t advocate for anything less that a manual push-type door lock release for the electric door locks. I have endeavored to create some type minimum performance description for the game room door hardware and labeled all other doors which are part of the egress path or that the public could use. One overriding issue that the building layout presents is that is a bit of a complex maze in itself, regardless of the escape games rooms use. It is difficult to determine which areas are exclusive to employee use and those which the public may access, and, the space is subject to reconfiguration of uses or expansion of game rooms into the spaces not currently used by the public. Please let me know if you have come to any decisions on the door lock requirements."
The inspector's answer:
"I agree with you about exit hardware but based on your occupancy loads, OSSC 1008.1.10 would require panic bars only at the exterior exits. Based on your drawings, individual spaces would only require modern accessible hardware as per 1008.1.9.1."
We met with the City officials before I asked these questions, and I was surprised that they were so non-concerned about locking people in dark rooms. What I'm most concerned about is any liability on my part as an architect. I made up a performance door hardware schedule with a qualification that the escape rooms get a manual release of any door locking mechanism on any door that is controlled by the escape room staff. The inspector's comment just states the obvious that all hardware be "accessible". I'm not sure whether that means no electric bolts (for the players, only a keypad can release those). And, if they are allowed, what if they fail or the staff flees the building to get away from a fire, leaving the players to their fate! I certainly will ask the inspector for more clarity, but it appears as though they are skirting my question – do you think I'm misinterpreting the answer? I found a few threads on this issue - here's one https://www.qrfs.com/blog/295-escape-room-fire-safety-are-escape-rooms-safe/ . There is also one post on this forum that refers to the issue quite well, https://www.thebuildingcodeforum.com/forum/threads/escape-rooms-special-amusement-building.14437/ , . Any comments or links to similar discussions would be appreciated? Also, all of the controls and video monitors in the escape room have been installed/jerry-rigged by the owner, but I can't imagine that with popularity of escape rooms that someone has not created some hardware with some emergency release mechanism - anyone familiar with how this is dealt with elsewhere?
Question #2 - "Game Room Emergency Lighting: We’ve had the electrical contractor out to the site and he said that emergency lighting would only be required at the exit signs, with a combo exit sign-lighting unit. The owner has expressed his desire to add no more safety features than the minimum code mandates. As far as my understanding of the code is correct, no room meets the normal assembly occupancy load threshold for code mandated emergency lighting. I advised the owner that because he has rooms where the lights will be turned off while customers are locked into rooms and those rooms have only switches outside of the locked room, he should provide emergency illumination in all game rooms (the game rooms may be updated, so even rooms that are currently lighted with their own switch controls, may become dark rooms in the future). Those customers in those dark rooms are supplied with pen flashlights, which you may consider a compensation for the lack of lighting and emergency lighting if an emergency occurs. Does Tualatin have a position on emergency lighting in these dark rooms or any escape games rooms?"
Inspector's answer:
"Our policy is as per OSSC 1006. While additional lighting is useful in an emergency, we do not mandate more or allow less than the code requires."
I'm less concerned with the lighting issue, but I personally would not want to be locked into a dark room while a fire is raging, all the while trying to find the clues to undo the lock. I sure hope we don't have more escape room deaths like the ones in Poland.
Question #1 - "Door Locks: I am still not sure how to address the door hardware issues for the escape rooms. You said you would discuss this with your colleagues and let us know. I don’t advocate for anything less that a manual push-type door lock release for the electric door locks. I have endeavored to create some type minimum performance description for the game room door hardware and labeled all other doors which are part of the egress path or that the public could use. One overriding issue that the building layout presents is that is a bit of a complex maze in itself, regardless of the escape games rooms use. It is difficult to determine which areas are exclusive to employee use and those which the public may access, and, the space is subject to reconfiguration of uses or expansion of game rooms into the spaces not currently used by the public. Please let me know if you have come to any decisions on the door lock requirements."
The inspector's answer:
"I agree with you about exit hardware but based on your occupancy loads, OSSC 1008.1.10 would require panic bars only at the exterior exits. Based on your drawings, individual spaces would only require modern accessible hardware as per 1008.1.9.1."
We met with the City officials before I asked these questions, and I was surprised that they were so non-concerned about locking people in dark rooms. What I'm most concerned about is any liability on my part as an architect. I made up a performance door hardware schedule with a qualification that the escape rooms get a manual release of any door locking mechanism on any door that is controlled by the escape room staff. The inspector's comment just states the obvious that all hardware be "accessible". I'm not sure whether that means no electric bolts (for the players, only a keypad can release those). And, if they are allowed, what if they fail or the staff flees the building to get away from a fire, leaving the players to their fate! I certainly will ask the inspector for more clarity, but it appears as though they are skirting my question – do you think I'm misinterpreting the answer? I found a few threads on this issue - here's one https://www.qrfs.com/blog/295-escape-room-fire-safety-are-escape-rooms-safe/ . There is also one post on this forum that refers to the issue quite well, https://www.thebuildingcodeforum.com/forum/threads/escape-rooms-special-amusement-building.14437/ , . Any comments or links to similar discussions would be appreciated? Also, all of the controls and video monitors in the escape room have been installed/jerry-rigged by the owner, but I can't imagine that with popularity of escape rooms that someone has not created some hardware with some emergency release mechanism - anyone familiar with how this is dealt with elsewhere?
Question #2 - "Game Room Emergency Lighting: We’ve had the electrical contractor out to the site and he said that emergency lighting would only be required at the exit signs, with a combo exit sign-lighting unit. The owner has expressed his desire to add no more safety features than the minimum code mandates. As far as my understanding of the code is correct, no room meets the normal assembly occupancy load threshold for code mandated emergency lighting. I advised the owner that because he has rooms where the lights will be turned off while customers are locked into rooms and those rooms have only switches outside of the locked room, he should provide emergency illumination in all game rooms (the game rooms may be updated, so even rooms that are currently lighted with their own switch controls, may become dark rooms in the future). Those customers in those dark rooms are supplied with pen flashlights, which you may consider a compensation for the lack of lighting and emergency lighting if an emergency occurs. Does Tualatin have a position on emergency lighting in these dark rooms or any escape games rooms?"
Inspector's answer:
"Our policy is as per OSSC 1006. While additional lighting is useful in an emergency, we do not mandate more or allow less than the code requires."
I'm less concerned with the lighting issue, but I personally would not want to be locked into a dark room while a fire is raging, all the while trying to find the clues to undo the lock. I sure hope we don't have more escape room deaths like the ones in Poland.
