Open stair as an AMOE within a story

[Sifu]

Always been confused by this. 2021 IBC.

IBC 1009.3.1 says an exit access stairway can't be used as an AMOE, unless from a mezzanine. 2018 commentary contain the following:
"but exit access steps within the same level,
such as steps in a corridor or room leading to an exit
or exit access doorway, cannot."

I have a space on a floor, with a raised stage. It requires 2 MOE's, and therefore 2 AMOE's per 1009.1. One AMOE is a ramp, the other is a step. (This is very similar to our previous discussion about raised platforms in schools, but this is not an existing building). By definition, isn't the step considered an exit access stairway? Per 2021 IBC 1009.3.1, the exit access stairway that connects levels in the same story are not permitted as part of the AMOE. This makes no sense to me. What am I missing?

 

[bill1952]

No help, but is either the ramp or stair directly from stage to audience?

Theres is good reasoning behind 1009.3.1 but I have forgotten it. Following this.

 

[steveray]

Bad code:

1009.3 Stairways. In order to be considered part of an
accessible means of egress, a stairway between stories shall
comply with Sections 1009.3.1 through 1009.3.3.

1009.3.1 Exit access stairways. Exit access stairways
that connect levels in the same story are not permitted as
part of an accessible means of egress.

Exception: Exit access stairways providing means of
egress from mezzanines are permitted as part of an
accessible means of egress.

But I think you really need to look at 1019.4 and .4...

1009.2 Continuity and components. Each required accessible
means of egress shall be continuous to a public way and
shall consist of one or more of the following components:
1. Accessible routes complying with Section 1104.
2. Interior exit stairways complying with Sections
1009.3 and 1023.
3. Exit access stairways complying with Sections
1009.3 and 1019.3 or 1019.4.

 

[Sifu]

The steps are off the front, discharging into the cafeteria/viewing area. It provides a clear path to the exit discharge. The ramp does the same thing.

The stair meets the requirements for an AMOE (there aren't really any because of sprinklers). It is 42" wide and has handrails on both sides. I just can't figure out how or why the code would disallow it, so I must not be understanding it correctly.

 

[Sifu]

Bad code:

1009.3 Stairways. In order to be considered part of an
accessible means of egress, a stairway between stories shall
comply with Sections 1009.3.1 through 1009.3.3.

1009.3.1 Exit access stairways. Exit access stairways
that connect levels in the same story are not permitted as
part of an accessible means of egress.

Exception: Exit access stairways providing means of
egress from mezzanines are permitted as part of an
accessible means of egress.

But I think you really need to look at 1019.4 and .4...

1009.2 Continuity and components. Each required accessible
means of egress shall be continuous to a public way and
shall consist of one or more of the following components:
1. Accessible routes complying with Section 1104.
2. Interior exit stairways complying with Sections
1009.3 and 1023.
3. Exit access stairways complying with Sections
1009.3 and 1019.3 or 1019.4.

I looked pretty hard at that to reconcile my confusion. At first I thought I had a eureka moment but then I realized that this section and the prohibitive section (1009.3.1) can coexist. In other words, an exit access stairway can be an AMOE, just not from an intermediate level within a story (unless it's a mezzanine) since in order to be an AMOE they must comply with 1009.3, which includes 1009.3.1.

 

[bill1952]

Just two notes. Sorry to be bearer of unwelcomed input. (Maybe that qualifies me to be a building official.)

1. If a person can walk to the stage, like your stairs allow, a person using a wheelchair must also be able to do that. The route to side and backstage does not comply. If you need exact language I'll look it up but iirc in section 8 of ANSI A117.1 and in ADA guidelines. A ramp in front or a lift is required if you have a fixed stair. Otherwise you are discriminating against people with disabilities.

2. The curtain you show is not allowed in the means of egress. I can't tell if it is stopped so there is always passage around the ends of it. It looks wall to wall.

I'm sure you and all of us have seen this violated. I just like to point it out since I insist my clients facilities comply with it. I also had a hand in drafting the language.

 

[steveray]

I assume this is what Bill is saying, but it's a tough one to fight:

1104.5 Location. Accessible routes shall coincide with or be
located in the same area as a general circulation path. Where
the circulation path is interior, the accessible route shall be
interior. Where only one accessible route is provided, the
accessible route shall not pass through kitchens, storage
rooms, restrooms, closets or similar spaces.


Maybe a code change is in order after the first AMOE for stages and platforms as well as mezz.....?

 

[Sifu]

Just two notes. Sorry to be bearer of unwelcomed input. (Maybe that qualifies me to be a building official.)

Input is never unwelcomed. Maybe disliked, maybe not agreeable. Never unwelcomed.

1. If a person can walk to the stage, like your stairs allow, a person using a wheelchair must also be able to do that. The route to side and backstage does not comply. If you need exact language I'll look it up but iirc in section 8 of ANSI A117.1 and in ADA guidelines. A ramp in front or a lift is required if you have a fixed stair. Otherwise you are discriminating against people with disabilities.

I assume you refer to the accessible route being along the circulation path. I do not see an issue with the one accessible route being the main entry door at the ramp. I don't believe they both need to be provided with a ramp. If I am wrong then the specifics would be appreciated.

2. The curtain you show is not allowed in the means of egress. I can't tell if it is stopped so there is always passage around the ends of it. It looks wall to wall.

I don't know what that curtain is. This is a preliminary review and the plans don't identify it. I am identifying it as an issue. My guess is it is a moveable partition or folding door. In it's current location (by scale) the area of the room may exceed the allowable area for a single exit access when it is closed. This will be addressed with further review.

I'm sure you and all of us have seen this violated. I just like to point it out since I insist my clients facilities comply with it. I also had a hand in drafting the language.

 

[bill1952]

When you're 71, it can be very disconcerting to not find something you know is there. On the other hand, finding it - in the unfortunate absence of hardcopy - is very satisfying.

IBC 1108.2 Performance areas. An accessible route shall directly connect the performance area to the assembly seating area where a circulation path directly connects a performance area to an assembly seating area. An accessible route shall be provided from performance areas to ancillary areas or facilities used by performers.

Also, from 2010 ADA Standards for Accessible Design:

206.2.6 Performance Areas. Where a circulation path directly connects a performance area to an assembly seating area, an accessible route shall directly connect the assembly seating area with the performance area. An accessible route shall be provided from performance areas to ancillary areas or facilities used by performers unless exempted by 206.2.3 Exceptions 1 through 7.

Just another turd in a swimming pool.

 

[steveray]

Or in 2021..

1109.2.8 Performance areas. An accessible route shall
directly connect the performance area to the assembly
seating area where a circulation path directly connects a
performance area to an assembly seating area. An accessible
route shall be provided from performance areas to
ancillary areas or facilities used by performers.

.Although I still say it says almost the same thing as 1104.5....unless there is commentary clarifying...

 

[Sifu]

The design does have a circulation path that directly connects the performance area to the viewing area. The ramp discharges to the same room. What I don't see is that every circulation path must do this. Nor does it say that the accessible route is required to be the same route as the circulation path. I would agree if the user were forced to go to great lengths and/or leave the room and go "around back" just to get onto the stage. I don't believe locating the ramp to the side of the stage, directly adjacent to it justifies moving it or adding another one. The stage is accessible, it does provide a direct route from the stage to the viewing area within the viewing area. They do not need to leave the viewing area to use it. The intent "that a person with mobility impairments could participate" is well met.

1104.5 uses the term "same area". What does that mean? 5'? 20'? Same room? Again, not forced to leave the building or go "around back" is kind of a threshold for me. This building has 5 sets of stairs to the 2nd level, does that mean I need 5 elevators? How close should the elevator be to each stair? If I locate the elevator next to one stair, it is pretty far from all the others. Have I discriminated against the people who are nearest to those other stairs?

I don't think the language of these code sections supports a definitive number for proximity to the circulation path. I do think it supports the intent that the accessible route has to be in the same room, with no need to feel ostracized by taking some circuitous route or asking for help. I don't think this design does that.

From the commentary:
Performance areas, such as stages, orchestra pits,
band platforms, choir lofts and similar spaces, must
be accessible. If there is a direct route from the seating
to the performance area, there must also be an
accessible route. For example, if steps are provided
from the assembly seating area to the stage within
the theater, then an accessible route (e.g., a ramp or
platform lift) to the stage must also be provided within
the theater. An accessible route must also be provided
to any ancillary areas, such as green rooms or
practice/warm-up rooms. The intent is that a person
with mobility impairments could participate in the
event.

I am comfortable with my "interpretation" about this issue. But still confused by the AMOE thing. I can't understand why it would be permitted from story to story (or mezzanine) but not for a couple of steps from an intermediate level.

 

[bill1952]

Or in 2021..

1109.2.8 Performance areas. An accessible route shall
directly connect the performance area to the assembly
seating area where a circulation path directly connects a
performance area to an assembly seating area. An accessible
route shall be provided from performance areas to
ancillary areas or facilities used by performers.

.Although I still say it says almost the same thing as 1104.5....unless there is commentary clarifying...

I mostly agree but in the drawing, both routes are "interior", and would not be too hard to convince people it complied. But consider any processional event - people getting awards, a choir, etc. - and those with mobility impairments have to go to a door, be out of sight, and re-enter from the back corner. It's clearly discriminatory.

I think I drafted those IBC words back in 1998 or 99. The trick was to not require an accesible route when there was not any other route. Regrettably, this has led to the work around of not building permanent steps (which excludes them from being a required means of egress) but use portable steps. It's then on the owner, not the designer, to not discriminate. And the quick fix after is a portable wheelchair lift, but portables meeting the relevant standard cost a lot more than basic lifts. In this case, there is (was?) a stair the transformed into a lift. Very popular in churches.

 

[bill1952]

The design does have a circulation path that directly connects the performance area to the viewing area. The ramp discharges to the same room. What I don't see is that every circulation path must do this. Nor does it say that the accessible route is required to be the same route as the circulation path. I would agree if the user were forced to go to great lengths and/or leave the room and go "around back" just to get onto the stage. I don't believe locating the ramp to the side of the stage, directly adjacent to it justifies moving it or adding another one. The stage is accessible, it does provide a direct route from the stage to the viewing area within the viewing area. They do not need to leave the viewing area to use it. The intent "that a person with mobility impairments could participate" is well met.

1104.5 uses the term "same area". What does that mean? 5'? 20'? Same room? Again, not forced to leave the building or go "around back" is kind of a threshold for me. This building has 5 sets of stairs to the 2nd level, does that mean I need 5 elevators? How close should the elevator be to each stair? If I locate the elevator next to one stair, it is pretty far from all the others. Have I discriminated against the people who are nearest to those other stairs?

I don't think the language of these code sections supports a definitive number for proximity to the circulation path. I do think it supports the intent that the accessible route has to be in the same room, with no need to feel ostracized by taking some circuitous route or asking for help. I don't think this design does that.

From the commentary:
Performance areas, such as stages, orchestra pits,
band platforms, choir lofts and similar spaces, must
be accessible. If there is a direct route from the seating
to the performance area, there must also be an
accessible route. For example, if steps are provided
from the assembly seating area to the stage within
the theater, then an accessible route (e.g., a ramp or
platform lift) to the stage must also be provided within
the theater. An accessible route must also be provided
to any ancillary areas, such as green rooms or
practice/warm-up rooms. The intent is that a person
with mobility impairments could participate in the
event.

I am comfortable with my "interpretation" about this issue. But still confused by the AMOE thing. I can't understand why it would be permitted from story to story (or mezzanine) but not for a couple of steps from an intermediate level.

Sorry if overlapping but in an ANSI A117.1 committee meeting, do slow.

Sifu - are you saying the proposed design complies with ADA and IBC as far as the accessible route between audience and stage?

I obviously don't and am pretty sure Access Board and the accessibility mavens at IBC don't. Going through the door and re-entering the stage simply is not direct.

 

[Sifu]

Yes, I think it does. As stated, I appreciate the input, all input. I think we just have to agree to disagree on this one. But, I will now always be looking for this issue, so right or wrong I will learn more from it every chance I get. If any of us ever find more information to validate one point of view or the other we should share it right here on this very forum. However, I will run this by the CBO to make sure he is aware of the possible compliance issue. Misery loves company right?

 

[bill1952]

I will pass along to Access Board and A117.1 committee people your interpretation along with drawing. And I'll post any relevant comments.

 

[Sifu]

I will pass along to Access Board and A117.1 committee people your interpretation along with drawing. And I'll post any relevant comments.

That would be awesome. Perhaps if I can misinterpret these codes others could too and some clarification would be warranted.

 

[bill1952]

I found little on access board site. It did mention for instance graduation. Everyone except the kid in the wheelchair walks straight to stage and gets their award (why stairs to stage are usually in pairs), the wheel chair kid rolls to other side, disappears, and then renters behind lectern. I just don't understand how the wheelchair route is "direct" or how it isn't discriminatory, and pretty sure that's how everyone in the room when discussed felt same.

But stand by - I'm trying to get their feedback in writing.

 

[Sifu]

I found little on access board site. It did mention for instance graduation. Everyone except the kid in the wheelchair walks straight to stage and gets their award (why stairs to stage are usually in pairs), the wheel chair kid rolls to other side, disappears, and then renters behind lectern. I just don't understand how the wheelchair route is "direct" or how it isn't discriminatory, and pretty sure that's how everyone in the room when discussed felt same.

But stand by - I'm trying to get their feedback in writing.

I see your point. I guess I am hung up on "direct" in this specific section regarding performance areas. My original thought is the bottom of the ramp being in the same room, and just a few feet from the stair. I do now have a better understanding of the logistics you are explaining and can see how it may be directing a user "around back". My comfort level may be shifting. I will eagerly await additional thoughts and information.

 

[bill1952]

I'll try to get the rational for 1009.3.1. I've heard it before and recall it made sense but just escapes me now.

 

[steveray]

I will pass along to Access Board and A117.1 committee people your interpretation along with drawing. And I'll post any relevant comments.

Good on you Bill!...And BTW, the ambulatory stall depth needs to be fixed to match the other stalls...I believe 2017 A117 still has it at 60" where the others can be 56" or 59" depending on the W/C...

I agree with the concept of "they are more hidden or removed" in a setting where they shouldn't be with the design shown, but hard to get to in IBC

 

[Sifu]

One last stab at this. I have two related issues.

The 1st, from my OP regards why the two-tread stair can't be an AMOE. A stair is allowed as an AMOE between stories, or from a mezzanine within a story, but not a 12" platform?

The 2nd, from the drift off of the OP, where I am conflicted between what Bill has pointed out and the language of the code. I certainly understand the point of view now but am still not certain the code language supports it. Bill, did you get any further info?

 

[bill1952]

I have some. ICC staff that deals most directly with accessibility agrees with me but "close". I have not heard back from Access Board folks but still on it.

I've asked the stage stair as AMOE and heard a reasonable - to some degree - reason but cannot recall it. Sorry.

Retiree pace.....

 

[Sifu]

Two schools, this is the second one. You can see the design has changed even though they (same design firm) do not yet know of my questions (unless they are really smart and troll this forum??). It has no "designated" stair as a "direct" access from the stage to the viewing area, only something that looks like a stair, walks like a stair, talks like a stair, but isn't called a stair, and is not provided with handrails so it can't be a stair. Is it better? This is also a preliminary review based on incomplete documents so I have no information about what is happening with the squiggly lines or closure across the front of the stage/platform.

 

[bill1952]

I think the steps to stage require a handrail at either side, and believe that is specifically addressed in the IBC. They are steps, will be used as steps, and as such should have handrails and the nosing marked. The IBC section on single steps is clear. Steps to stage are one of the most hazardous steps I have seen, including many awards shows on tv. It's the most common accident on stages.

As far as accessibility IMHO I believe this clearly discriminates against people with disabilities. One kid bonds up to stage for an award and another kid who uses a wheelchair has to go out of sight and reappear up stage. Not fair.

I'm sorry I don't have a response from access board. I have continued to get a response. I think I'll ask my theatre consulting colleagues on their opinions.