Single Exit from A2 Occupied Roof via Exterior Exit Stair Discharging at Grade

[bellbutler]

I'm looking for any IBC code commentary or tech bulletins that might provide some additional clarification on this. Single exits have come up a lot on the forums, and I've read through the past posts; which all described buildings a good bit larger than what we are working with, so were not really relevant. We are on 2015 IBC.

We have a 1600sf freestanding A2 building with a small roof deck ~700sf open to the sky and bounded by 42" guardrails accessed only via an exterior stair that meets the IBC definition and 1027 requirements for 'Exterior Exit Stairway.' We intentionally sized the roof deck to be less than 49 occupants and less than 75' travel distance from most remote point to bottom of the stair which discharges at grade and the public way. Our position is that we meet the criteria established by '1006.3.2 Single exits (under 1006.3 Egress from stories and occupied roofs)' by the second condition, code excerpted below.

The AHJ is challenging this as they interpret 'discharge directly' to mean an exit door that opens directly to the outside on the ground floor only. We've provided the code documentation that indicates our Exterior Exit Stairway meets 1027 requirements and per IBC definition of 'exit' constitutes an exit. Our position is that you enter the 'Exit' (i.e. the stair) at the roof level and discharge from the 'Exit' at grade and thus are inline with code requirements.

They've offerered to interpret the roof deck as a mezzanine and indicated that would make it compliant, however I feel uneasy about formally documenting an occupied roof as a mezzanine as in my opinion it clearly does not meet the code definition of a mezzanine as it is not open to any interior space at all. They have a formal appeal process which we are considering pursuing as the Owner would prefer not to have 2 stairs given the small size of the roof deck.

1006.3.2 Single Exits

A single exit or access to a single exit shall be permitted from any story or occupied roof where one of the following conditions exists:

1. The occupant load, number of dwelling units and common path of egress travel distance does not exceed the values in Table 1006.3.2(1) or 1006.3.2(2).
2. Rooms, areas and spaces complying with Section 1006.2.1 with exits that discharge directly to the exterior at the level of exit discharge, are permitted to have one exit or access to a single exit.

Relevant definitions:
(my opinon is code should revise 'common path' to 'exit access travel distance' as by nature of a single exit there is no common path, but that's neither here nor there)

COMMON PATH OF EGRESS TRAVEL. That portion of the exit access travel distance measured from the most remote point within a story to that point where the occupants have separate and distinct access to two exits or exit access doorways.

EXIT. That portion of a means of egress system between the exit access and the exit discharge or public way. Exit components include exterior exit doors at the level of exit discharge, interior exit stairways and ramps, exit passageways, exterior exit stairways and ramps and horizontal exits.

EXIT DISCHARGE. That portion of a means of egress system between the termination of an exit and a public way.

EXIT DISCHARGE, LEVEL OF. The story at the point at which an exit terminates and an exit discharge begins.

EXTERIOR EXIT STAIRWAY. An exit component that serves to meet one or more means of egress design requirements, such as required number of exits or exit access travel distance, and is open to yards, courts or public ways.

 

[e hilton]

Mezzanine. An intermediate level or levels between the floor and ceiling of and story and in accordance with sec 505.

505.2.3 Openness. A mezzanine shall be open and unobstructed to the room in which such mezzanine is located except for walls not more than 42” in height.

 

[bellbutler]

Mezzanine. An intermediate level or levels between the floor and ceiling of and story and in accordance with sec 505.

505.2.3 Openness. A mezzanine shall be open and unobstructed to the room in which such mezzanine is located except for walls not more than 42” in height.

Yes, I know the occupied roof is definitely not a mezzanine, however since the AHJ wants to interpret it that way it is their discretion. I feel a bit uneasy about documenting it that way, but an occupied roof is probably a safer condition since there is no ceiling to cause smoke and gas accumulation.

 

[RLGA]

I know we had a discussion in a previous thread regarding what "directly" means, and you have shown the two obvious interpretations. I lean toward the conservative one, which is your AHJ's position. However, it could somewhat reasonably be interpreted per your position.

The operative word is "directly." All exits discharge at the level of exit discharge, so it does not make sense to me why they would add "directly" if all exits eventually take you to the level of exit discharge. When you enter an exit stair, you are not discharged directly to the exterior--you have to go down the stair, and then it discharges to the exterior. It is by no means direct in my opinion.

However, you can use item #1 if the travel distance to the exterior exit stair is less than 75 feet per Table 1006.3.2(2).

 

[bellbutler]

I know we had a discussion in a previous thread regarding what "directly" means, and you have shown the two obvious interpretations. I lean toward the conservative one, which is your AHJ's position. However, it could somewhat reasonably be interpreted per your position.

The operative word is "directly." All exits discharge at the level of exit discharge, so it does not make sense to me why they would add "directly" if all exits eventually take you to the level of exit discharge. When you enter an exit stair, you are not discharged directly to the exterior--you have to go down the stair, and then it discharges to the exterior. It is by no means direct in my opinion.

However, you can use item #1 if the travel distance to the exterior exit stair is less than 75 feet per Table 1006.3.2(2).

I do understand their (and your) position and interpretation; the 'directly' is the crux and a bit weird that it is added at all, it's either redundant or carries some greater meaning that isn't actually defined in the code and subject to interpretation.

I don't ever work on tall buildings, but I think about early in my career when I was taught to disregard any laymen's definition of 'exit' and understand the IBC definition; it was a revelation to understand that the interior exit stair in high rise building is all the 'exit' and we don't even have to consider how far one travels down that stair per code. The travel to the entrance of that exit is what matters. I suppose I am thinking about this the same way; the exit definitely discharges directly to the exterior at the level of exit discharge, and there isn't anything prohibiting entering the exit above the level of exit discharge. Given that the code section is about 'egress from an occupied roof' one would assume that it is by nature at least one level up.

Travel distance by code definition in IBC is measured to the entrance of the exit, not to the bottom of the exit stair and we don't have to account for travel distance in the exit itself (although we did here to be more conservative, and because our home AHJ uses NFPA 101 which does specify that travel in the exit stair itself must be included for single exits- the project in question is not subject to NFPA 101 though).

We can't use condition 1 and Table 1006.3.2(2) since it is A2, and even though we are less than 49 persons on the roof it isn't a B occupancy because the main building occupancy is A2 and the roof is accessory. The downstairs is actually about half A2 / half B since the kitchen, bathrooms, and other support spaces take up a decent amount of space and most of the seating is outside on a patio so I suppose I could frame it as a B occupancy with A2 accessory, but I don't really think that would be in the spirit of the code.

 

[bellbutler]

I know we had a discussion in a previous thread regarding what "directly" means, and you have shown the two obvious interpretations. I lean toward the conservative one, which is your AHJ's position. However, it could somewhat reasonably be interpreted per your position.

The operative word is "directly." All exits discharge at the level of exit discharge, so it does not make sense to me why they would add "directly" if all exits eventually take you to the level of exit discharge. When you enter an exit stair, you are not discharged directly to the exterior--you have to go down the stair, and then it discharges to the exterior. It is by no means direct in my opinion.

However, you can use item #1 if the travel distance to the exterior exit stair is less than 75 feet per Table 1006.3.2(2).

Could you share the thread with the directly discussion? I couldn't find it. The AHJ acknowledged this hinges on the interpretation of directly. Google turns up 2 definitions, which interestingly enough are basically my interpretation and the AHJ's or your interpretation- one that indicates stuff in between, but unwaveringness in the directly along a path of travel, and one that says nothing in between.

1.
without changing direction or stopping.
"they went directly to the restaurant"

2.
with nothing or no one in between.
"the decisions directly affect people's health"

As IBC does not define it, I went back through 1027 to see if it is used in relation to Exterior Exit Stairway, but it is not. It is however used in the description of Interior Exit Stairways, that I think supports my use of the word in the spirit of the first definition as directly being along a path of travel that does not deviate from that path. I wish there was a formal interpretation as it really comes down to semantics.

1023.1 General

Interior exit stairways and ramps serving as an exit component in a means of egress system shall comply with the requirements of this section. Interior exit stairways and ramps shall be enclosed and lead directly to the exterior of the building or shall be extended to the exterior of the building with an exit passageway conforming to the requirements of Section 1024, except as permitted in Section 1028.1. An interior exit stairway or ramp shall not be used for any purpose other than as a means of egress and a circulation path.

 

[RLGA]

@bellbutler, you may have a point about the use of "directly" used elsewhere, but I do not think Section 1023.1 fully supports it. However, I would look at Section 1028.1 where it states "Exits shall discharge directly to the exterior of the building." There are exceptions, so if an exception applies, then the exit is not "directly" to the exterior. You may have something here...

Are you an ICC member? If so, maybe submit a request for a technical opinion on this issue to see what they say.

 

[e hilton]

however since the AHJ wants to interpret it that way it is their discretion.

I would not feel comfortable interpreting something in a way that it so clearly is not. What happens if that person gets hit by a bus next month, and the replacement says “no way”.

 

[RLGA]

I would not feel comfortable interpreting something in a way that it so clearly is not. What happens if that person gets hit by a bus next month, and the replacement says “no way”.

That is why I also ask for it in writing--I was burned by such a situation in the past (not by a bus, but by department staff layoffs following the 2008 recession).

 

[steveray]

How did you get the rooftop deck to be non-accessible?

 

[bellbutler]

I would not feel comfortable interpreting something in a way that it so clearly is not. What happens if that person gets hit by a bus next month, and the replacement says “no way”.

I agree and I'm not really comfortable with it, which is why I am trying to make a case for the interpretation I have for single exits from an occupied roof.

 

[bellbutler]

How did you get the rooftop deck to be non-accessible?

standard elevator exemption. ada- title 3 28 C.F.R. 36.401(d); IBC has it as well in ch 11, but I don't know the citation off hand.

 

[bellbutler]

That is why I also ask for it in writing--I was burned by such a situation in the past (not by a bus, but by department staff layoffs following the 2008 recession).

agreed, I have an email but it isn't like an official memo or anything.

 

[bellbutler]

@bellbutler, you may have a point about the use of "directly" used elsewhere, but I do not think Section 1023.1 fully supports it. However, I would look at Section 1028.1 where it states "Exits shall discharge directly to the exterior of the building." There are exceptions, so if an exception applies, then the exit is not "directly" to the exterior. You may have something here...

Are you an ICC member? If so, maybe submit a request for a technical opinion on this issue to see what they say.

I'm not a member, but after your comment I did just go look at the published 'committee interpretations' and it looks like there are some things on here that may support my interpretation. I'm diving into it right now, but I'll bring my findings back to the thread. I've been a long time lurker on this forum and have found tons of old threads helpful for code questions!

 

[RLGA]

agreed, I have an email but it isn't like an official memo or anything.

If it is from the city's official domain (e.g., xxx@anytown.gov), then it is just as if you received it on their official letterhead. The only issue would be if the person had the authority to make such determinations.

 

[bellbutler]

@bellbutler, you may have a point about the use of "directly" used elsewhere, but I do not think Section 1023.1 fully supports it. However, I would look at Section 1028.1 where it states "Exits shall discharge directly to the exterior of the building." There are exceptions, so if an exception applies, then the exit is not "directly" to the exterior. You may have something here...

Are you an ICC member? If so, maybe submit a request for a technical opinion on this issue to see what they say.

I read through 1028.1 comprehensively now, and I do believe this supports my interpretation and is a much stronger case as the exact same phrase 'discharge directly' is used. It is clear from the exceptions as well that when one is not required to 'discharge directly' they are permitted to leave the actual Exit and traverse other parts of the building before actually arriving at the Exit Discharge that takes them to the public way, which is not the condition we have. I'll reference this for the AHJ and see what their thoughts are.

I've kind of dug into this because we have done single exits from upper levels in numerous projects in our home jurisdiction of New Orleans. Because of the nature of the urban fabric meeting remoteness requirements in existing historic buildings (think French Quarter) is really hard, so if you can't meet single exit criteria you must do an appeal; however when we can meet single exit criteria we cite it and it isn't challenged. Projects are regularly designed around single exit criteria. NFPA 101 is actually more stringent than IBC (my and our AHJ interpretation) for single exits for some occupancies as well- like accounting for travel distange within the actual Exit itself rather than just common path or exit access travel.

I realized that 2015 ICC interpretations are not available and while there are some 2012 ICC interpretations available about these code sections, they actually changed and reorganized fairly substantially between the 2012 and 2015 so they aren't entirely relevant.

If it is from the city's official domain (e.g., xxx@anytown.gov), then it is just as if you received it on their official letterhead. The only issue would be if the person had the authority to make such determinations.

That does make sense, but given all the correspondence we have via email now with plan reviewers and code administrators I prefer something more formal for such significant code deviations. I'm glad that the AHJ has been accommodating enough to offer us this alternate interpretation and we will definitely take it if they don't agree after reviewing the 'discharge directly' references; and they probably would give us something more official if we ask for it. They've been really great to work with and willing to hear all my arguments & rationale for my interpretation, but they've essentially said 'they've always done it this way' so that's how they do it- which is also entirely valid within the code as they have ultimate discretion anyway.

 

[steveray]

So the 3000ft maybe?

1104.4 Multistory buildings and facilities. At least one
accessible route shall connect each accessible story and mezzanine
in multilevel buildings and facilities.
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:

Of course if I were strict the roof isn't a story or mezzanine....So the first floor is accessible?

 

[bellbutler]

So the 3000ft maybe?

1104.4 Multistory buildings and facilities. At least one
accessible route shall connect each accessible story and mezzanine
in multilevel buildings and facilities.
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:

Of course if I were strict the roof isn't a story or mezzanine....So the first floor is accessible?

Yes, we meet the criteria for an exemption for an elevator and have the same services on the roof deck as the ground level.

 

[JPohling]

Yes, we meet the criteria for an exemption for an elevator and have the same services on the roof deck as the ground level.

Except the outdoors and the view......so not a like environment.

 

[bellbutler]

Except the outdoors and the view......so not a like environment.

It's certainly subject to some differences, but the same could be said of the actual examples cited in ADA for this exact situation where they allow exemptions for accesible routes to upper levels. This isn't in question though and not what the thread is about. The single exit per Ch 10 is in question, and it does meet the criteria for an ADA accessible means of egress- because that is required regardless of accessible ingress which we don't have and are not required to have.

 

[steveray]

No...if you are not accessible you don't need an AMOE...

1009.1 Accessible means of egress required. Accessible
means of egress shall comply with this section. Accessible
spaces shall be provided with not less than one accessible
means of egress.

 

[bellbutler]

No...if you are not accessible you don't need an AMOE...

1009.1 Accessible means of egress required. Accessible
means of egress shall comply with this section. Accessible
spaces shall be provided with not less than one accessible
means of egress.

We default to ADA since it is federal legislation (so you can be sued for it anywhere) regardless of what the AHJ uses, so I am not as familiar with IBC accessibility code since ADA seems to be more stringent. The inaccessible level must still have accessible egress (i.e. 48" between stair handrails) and any restrooms or other things on an inaccessible level still have to be ADA compliant per the ADA elevator exemption. Maybe IBC doesn't require that, but even if code enforcement doesn't check ADA it is still a federal law that businesses have to comply with. ADA text excerpted from elevator exemption - Title III, 28 cfr 36.401(d).

• (3) The elevator exemption set forth in this paragraph (d) does not obviate or limit, in any way the obligation to comply with the other accessibility requirements established in paragraph (a) of this section. For example, in a facility that houses a shopping center or shopping mall, or a professional office of a health care provider, the floors that are above or below an accessible ground floor and that do not house sales or rental establishments or a professional office of a health care provider, must meet the requirements of this section but for the elevator.

 

[redeyedfly]

I don't understand the confusion about the word "directly". It certainly isn't redundant. 1028 defines exit discharge and clarifies the intent of "directly"; 1028 is the definition of "directly". Once you're in the exit (exterior egress stair) it must discharge to the exterior, meaning it can't go through another space unless it meets the requirements of 1028. Exit passageways and lobby exceptions are the most common alternates.
Your AHJ is embarrassingly wrong.

 

[bellbutler]

I don't understand the confusion about the word "directly". It certainly isn't redundant. 1028 defines exit discharge and clarifies the intent of "directly"; 1028 is the definition of "directly". Once you're in the exit (exterior egress stair) it must discharge to the exterior, meaning it can't go through another space unless it meets the requirements of 1028. Exit passageways and lobby exceptions are the most common alternates.
Your AHJ is embarrassingly wrong.

I agree completely; unfortunately the AHJ also has the authority to interpret however they want. It may be a bit telling that they have a very formal appeal process that ends at the state level with lawyers interpreting the language.