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Sifu,
In reading the various sections applicable to Stairways; in the `09,
...the `12 & the `15 IBC, ...the `09 DOES require a minimum of 80
inches of headroom, while the `12 & the `15 editions apply only to
those portions of a building that are "occupiable".
If you are desiring to enforce the `09 IBC, See Section 1009.2
as the applicable Section.
IMO, ...you do not have a MOE, according the definition listed
in Ch. 10 of the `09 IBC: "MEANS OF EGRESS. A continuous
and unobstructed path of vertical and horizontal egress travel
from any occupied portion of a building or structure to a
publicway. A means of egress consists of three separate and
distinct parts: the exit access, the exit and the exit discharge."
There's that pesky term of "occupiable portion of a building"
again, however, ...you DO have a stairway, ...just not an MOE
stairway.
Since your Stairway is not intended for the thundering herds
to utilize, ...persons using the Stairway are, IMO, ...expected
to have and actually use, a higher degree of awareness when
using it [ i.e. - not bumping their heads on protruding
objects ].
Hope this helps !
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