Mezzanine - Accessible Means of Egress vs. Accessible Route

[DTBarch]

Given:

Type III-B Fully Sprinklered Warehouse building containing Group B and S-1 under 1012 IBC

Under design is a 2,833sf mezzanine which will contain a 996sf enclosed office area along with a 1,837sf storage area. No public access on the mezzanine, just employees of the business and supply storage. Mezzanine will be served by a single, unenclosed stairway. CPET exit distance from most remote corner of mezz to the bottom of stair is 80 feet at which point there are two directions of egress travel available. Our occupant load is 10 + 4 = 14 Occupants total

IBC Code Commentary states that "Because mezzanines that comply with Section 505 are considered a portion of the story in which they are located in accordance with Section 505.2, the exit access stairway leading from it is not required to be enclosed. The enclosure provisions of Section 1009.3 do not apply to stairways that are contained within a single story"

Section 1007.1 requires us to provide one Accessible Means of Egress, which can be a stairway compliant with Section 1007.3 HOWEVER, Section 1007.3 states, "Exit access stairways that connect levels in the same story are not permitted as part of an accessible means of egress"

That seems to say that we can have an open stairway serving the mezzanine, BUT it can not be considered a part of the required Accessible Means of Egress.

Question:

All of that leads to my question, does Section 1104.4 exempt our mezzanine from needing to be accessible, and therefore exempt us from needing to have an Accessible Means of Egress? In other words, does Section 1104.4 trump 1007.1? Section 1104.4 states, "At least one accessible route shall connect each accessible level, including mezzanines, in multilivel buildings and facilities" with Exception 1 reading, "An accessible route is NOT required to stories and mezzanines that have an aggregate area of not more than 3,000sf and are located above and below accessible levels."

A fair amount of counter concepts occuring here making it less than crystal clear. The code seems to say that we DO NOT need an accessible route, but we DO need an accessible means of egress. Similar but different terminology. Bottom line, my question is can we utilize a single unenclosed exit from the mezzanine?

Did my best to make my question as non-confusing as possible, but not sure I succeeded! Thanks to all in advance for your feedback.

 

[steveray]

Section 1007.3 states, "Exit access stairways that connect levels in the same story are not permitted as part of an accessible means of egress"

New wording in 2012....I do not think I understand it....They must be trying harder to get a protected exit for people who need it...

But...if it is not an accessible level, no AMOE is required.....IMO

 

[Codegeek]

If the total (aggregate) square footage between the mezzanine and the floor below is less than 3,000 square feet, than an accessible route is not required. If an accessible route is not required, then an accessible means of egress would not be required. This can be found in the commentary to the IBC in Section 1007.

If the total square footage exceeds 3,000 square feet, than an accessible route is required to the mezzanine and at least one accessible means of egress must be provided from the mezzanine.

 

[DTBarch]

Codegeek - Since we do not have a floor below the accessible level (ground floor slab on grade), I do not believe the aggregate computation is in play.

As I'm reading it, the "floor below" as described in the commentary, is specifically speaking about a condition where "...a building had a floor area of 2,000sf above the "entrance level" and a floor area of 2,000sf below the "entrance level", the "aggregate" is 4,000sf."

In our specific case, the "entrance level" is the main warehouse slab on grade, therefore there is no area to add to the mezzanine area...correct?

 

[Codegeek]

The aggregate means the main floor and the mezzanine level combined. If the mezzanine is 2883 square feet than the aggregate square footage has to be more than 3000 as the mezzanine is limited in size based on the area limitations to be considered a mezzanine rather than a floor/story.

 

[steveray]

CG.....I believe this exception applies just to the mezzanine(s) square footage (not the floor served)because you could put in six 2999ft one to get around it otherwise.....

Exceptions:

1. An accessible route is not required to stories and mezzanines that have an aggregate area of not more than 3,000 square feet (278.7 m2) and are located above and below accessible levels. This exception shall not apply to:

 

[Codegeek]

CG.....I believe this exception applies just to the mezzanine(s) square footage (not the floor served)because you could put in six 2999ft one to get around it otherwise.....Exceptions:

1. An accessible route is not required to stories and mezzanines that have an aggregate area of not more than 3,000 square feet (278.7 m2) and are located above and below accessible levels. This exception shall not apply to:

By definition aggregate means to add together the areas. If there are multiple mezzanines which when added to the main floor level exceed 3000 square feet, then the mezzanine(s) must be accessible.

 

[steveray]

From commentary: I know it is not code...but it is what we go with...

At least one accessible route is required between levels in a facility. This requirement does not mandate an elevator. The accessible route between levels can be via ramps, platform lifts (where permitted), limited use/limited access (LULA) elevators, passenger elevators, etc. The intent of the exceptions is to allow limited areas to be inaccessible without restricting access to services available to the general public.

Exception 1 addresses conditions under which it may not be practical or economical to provide an accessible route in multilevel buildings. The primary economic consideration is that, in the vast majority of circumstances, the means of providing an accessible route to floor levels above or below the entrance level of the building will be by an elevator. This exception applies to levels above and below the entry level that have an aggregate area of 3,000 square feet (279 m2) or less. For example, if a building had a floor area of 2,000 square feet (186 m2) above the entrance level and a floor area of 2,000 square feet (186 m2) below the entrance level, since the aggregate area of the basement and second floor is 4,000 square feet (372 m2), at least one of the two floor areas would be required to be connected to the entrance level by an accessible route.

 

[Codegeek]

I learned something today, thank you steveray. I contacted ICC as it wasn't making sense to me based on my previous experience with that language. If there was more than one mezzanine, or another floor or basement, and their combined total was more than 3,000 square feet then they would have to be accessible.

 

[DTBarch]

Thank you both for your time in working through this question. As always, I much appreciate it.