Smaller egress windows in retrofit

[texasbo]

Re: Smaller egress windows in retrofit

First windows are never a means of egress (think exit access, exit, exit discharge) they are a means of escape.

Secondly, even if you misconstrue the code to include emergency escape and rescue openings as a means of egress, the current windows do not provide one so there is no reduction in protection.

A typical window replacement has no effect on the existing level of protection afforded by the means of egress...and again in this case there isn't an existing compliant means of escape either.

This type of twisted, perverted logic constitutes a very real threat to the public. Following such ridiculous notions would lead to the conclusion that the removal of a necessary structural element in a structurally unsound building does not constitute an increased level of noncompliance. This type of reasoning is patently careless. Thank you again for illustrating how important it is for us to protect the public.

 

[texasbo]

Re: Smaller egress windows in retrofit

Non-compliant to non-compliant isn't a reduction in compliance.

You're exactly right! And if they were replacing noncompliant windows with the same noncompliant windows, they'd be just fine by code.

Please provide a code citation for your position.

501.2, IECC: "An existing building or portion thereof shall not be altered such that the building becomes less safe than its existing condition"

Exception: (paraphrased) unless it complies with the IBC.

Brudgers, are you serious? I mean this is way out there, even for you.

 

[High Desert]

Re: Smaller egress windows in retrofit

brudgers:

You have to be kidding, right? Would it also be okay to change out the main 3 foot egress door to a smaller one because "they didn't want to disturb the lead paint"?

texasbo provided the correct code reference.

 

[Yikes]

Re: Smaller egress windows in retrofit

Wow, thanks to everyone for the responses so far!

FYI,

1. There are no sprinklers in these existing buildings, so no easy exceptions.

2. This project is on California, which never adopted the IRC, so our version of the IBC still applies (that's why I posted under commercial code).

3. What I'm hearing so far is what I suspected - -we all intuitively get an uneasy feeling about making a non-compliant opening even smaller than before, but it's not easy to hang our hat on a specific code section.

4. The project was built under the old UBC. The thing is, we believe that there is a wave of these kind of rehab projects coming up, so the philosophical approach we're developng here should be transferable to future projects throughout our state.

5. The actual rehab work could be a real mess. The surrounding wall is CMU, so it's expensive to enlarge the opening. There's been a lot of decorative trim (with lead-based paint) slapped on the interior and exterior face of the windows, so removal of the window would ential removal of a lot of trim, and from an abatement standpoint, would be like unraveling the thread of a hem. The only alternative short of full abatement ($$$ and removal of occupants) is encapsulation.

How about this approach:

California Building Code 3410 (and I assume the IBC as well) has a somewhat complex formula for determining "compliance alternatives". Let's assume (subject to verification):

* The building met code at the time it was built.

* The bedroom windows do not meet the current IBC for emergency escape/rescue.

* The retrofit would make them even "less compliant".

* Is there a "compliance alternative" calc that would make some other component of the overall life safety/exit system more safe, such that it would compensate for makign the windows smaller?

For example, we typically think of such rescue windows being used to escape a fire. Well, if this building was constructed in the 1950s, I believe that the smoke detectors wthat were added about 25 years ago have increased the safety of the building as compared to its first day of occupancy... probably would do more to save lives than the windows themselves??

However, if I do a 3410 calculation, there is no category or value for egress windows.

Could you make a judgement call regarding a point value for smoke detectors and egress windows?

 

[brudgers]

Re: Smaller egress windows in retrofit

brudgers:You have to be kidding, right? Would it also be okay to change out the main 3 foot egress door to a smaller one because "they didn't want to disturb the lead paint"?

texasbo provided the correct code reference.

In my copy of IEBC 501.2 is about permitted materials for repairs. I think he's looking at an old version as alterations are now in chapter six...I do applaud the fact that he actually opened a code book however.

The lead paint is also a non-conforming condition and is a substantial environmental hazard.

If the existing windows were conforming, it would be a clear. Replace them with a conforming window.

But that's not the case.

Instead, it's fishing party for an excuse to deny the permit.

The proposed solution eliminates one none conforming condition (lead paint) and allow another non-conforming condition to continue.

It's not a perfect solution, but that's the way the EIBC is intended to work.

 

[brudgers]

Re: Smaller egress windows in retrofit

egress windows?

There's no such thing as an "egress window."

Let me put it another way.

The windows are not emergency escape and rescue openings because they were not part of the code at the time the building was constructed.

No matter how you change the size of the window, you are not affecting an emergency escape and rescue opening because:

1. They were never designed or intended as such.

2. The do not meet the current requirements.

You wouldn't argue that reducing the water service size will effect the sprinklers in an unspriklered building...TB excepted.

 

[Alias]

Re: Smaller egress windows in retrofit

Yikes -

Check out CBC Section 3410.2.4 - Alterations & repairs - "An existing building or portion thereof, which does not comply with requirements of this code for new construction, shall not be altered or repaired in such a manner that results in the building being less safe or sanitary than such building is currently."

I would conclude that the new windows, as long as they are not reducing the size, is allowed under the CBC. Also, if it is a lead abatement (safety) and with the smoke detectors (safety) you have upgraded an existing building to the best it can be under the circumstances.

Here, I have homeowners who always want to know why they need a permit to retrofit their windows. I tell them that the windows must be the same size or larger that they are replacing and quote this section. I can't tell you how many 'lumberyard sale windows' I've tagged after the owner installs a smaller window in the bedroom.

Sue, living in distressed CA

 

[Heaven]

Re: Smaller egress windows in retrofit

A monitored fire alarm system would go a long way toward equivilancy.

 

[JBI]

Re: Smaller egress windows in retrofit

"Emergency Egress" is an older term, based on getting out in an emergency. Prior to the advent of SCOT packs as standard issue for most fire depts, 'rescue' was a limited occurence.

"Emergency Escape and Rescue" is the current term and reflects the underlying advances that have been made.

For those who have been in Codes long enough (on EITHER side of the counter) it is easy slip up and use the old language. It is very likely that at the time of construction, the requirements would have been for 'emergency egress' windows.

That said, any reduction in area (or in a non-compliant dimension) is both a bad idea and violative of the Code. The sections have been quoted (by others even if you didn't like my Code path... and you'd be justified in that, BTW). A Code Officials responsibility is to ensure Code compliance to the best of our ability. Allowing a too-small bedroom window to be made smaller would not meet that standard. A Code Officials job is not to approve plans 'just because'.

"How can I approve these plans?" By verifying Code Compliance in the design to the best of my ability.

 

[texasbo]

Re: Smaller egress windows in retrofit

Yikes said:

3. What I'm hearing so far is what I suspected - -we all intuitively get an uneasy feeling about making a non-compliant opening even smaller than before, but it's not easy to hang our hat on a specific code section.

I agree with everything you said except for this. Several members cited specific code sections prohibiting what is proposed. And yes, I quoted 2003 code. Big deal, I cited the code edition up front, and the same language is in subsequent code editions.

3403.2.3.2, 2006 IBC says that alterations must conform to the requirements for a new structure, so some might even argue the new window would have to meet all current Emergency Escape requirements...

Alias said:

Here, I have homeowners who always want to know why they need a permit to retrofit their windows. I tell them that the windows must be the same size or larger that they are replacing and quote this section. I can't tell you how many 'lumberyard sale windows' I've tagged after the owner installs a smaller window in the bedroom. Sue, living in distressed CA

It's not just ignorant homeowners who must be watched.

 

[brudgers]

Re: Smaller egress windows in retrofit

"Emergency Egress" is an older term, based on getting out in an emergency. Prior to the advent of SCOT packs as standard issue for most fire depts, 'rescue' was a limited occurence. "Emergency Escape and Rescue" is the current term and reflects the underlying advances that have been made.

For those who have been in Codes long enough (on EITHER side of the counter) it is easy slip up and use the old language. It is very likely that at the time of construction, the requirements would have been for 'emergency egress' windows.

That said, any reduction in area (or in a non-compliant dimension) is both a bad idea and violative of the Code. The sections have been quoted (by others even if you didn't like my Code path... and you'd be justified in that, BTW). A Code Officials responsibility is to ensure Code compliance to the best of our ability. Allowing a too-small bedroom window to be made smaller would not meet that standard. A Code Officials job is not to approve plans 'just because'.

"How can I approve these plans?" By verifying Code Compliance in the design to the best of my ability.

Escape is the original concept from the NFPA. It still exists there in NFPA 101...see A24.2 NFPA 101, 2003

The concept of escape is incorporated directly into IBC.

Confusing it with egress, is in my opinion, symptomatic of a lack of understanding.

I've never met a person who called it an "egress window" who understood the difference between egress and escape and could apply them within the appropriate domains.

If you've been calling them "egress windows" for a long time, that's not exactly a feather in your cap.

 

[texasbo]

Re: Smaller egress windows in retrofit

Brudgers said:

If you've been calling them "egress windows" for a long time, that's not exactly a feather in your cap.

Yes, and I guess the terminology that JD used on an internet forum is actually more important than the subject of life safety as it relates to the question at hand. His application was correct, regardless of what he called it. I guess the next thing you're going to do is start pointing out typo's. Getting a little desperate there...

How about instead of nitpicking semantics, you just limit your comments to whether it complies with the code or not as requested by the OP. And in this case, it clearly does not.

 

[brudgers]

Re: Smaller egress windows in retrofit

Brudgers said:

If you've been calling them "egress windows" for a long time, that's not exactly a feather in your cap.

Yes, and I guess the terminology that JD used on an internet forum is actually more important than the subject of life safety as it relates to the question at hand. His application was correct, regardless of what he called it. I guess the next thing you're going to do is start pointing out typo's. Getting a little desperate there...

How about instead of nitpicking semantics, you just limit your comments to whether it complies with the code or not as requested by the OP. And in this case, it clearly does not.

I know what the code actually says isn't a big deal to you.

Please pardon those of us who take it a bit more seriously.

 

[kilitact]

Re: Smaller egress windows in retrofit

Heaven wrote:

A monitored fire alarm system would go a long way toward equivilancy.

I would agree.

 

[texasbo]

Re: Smaller egress windows in retrofit

Brudgers said:

I know what the code actually says isn't a big deal to you.

You mean like when I quoted code sections that specifically prohibit what you are advocating:

texasbo: 501.2, IECC: "An existing building or portion thereof shall not be altered such that the building becomes less safe than its existing condition"

Brudgers said:

Please pardon those of us who take it a bit more seriously.

You mean like when you fly by the seat of your pants like this:

The lead paint is also a non-conforming condition and is a substantial environmental hazard.If the existing windows were conforming, it would be a clear. Replace them with a conforming window.

But that's not the case.

Instead, it's fishing party for an excuse to deny the permit.

The proposed solution eliminates one none conforming condition (lead paint) and allow another non-conforming condition to continue.

It's not a perfect solution, but that's the way the EIBC is intended to work.

Thanks for letting us all know how you'd seriously cobble together a solution. A bad solution. One problem though: you've managed to confuse the words seriously and sloppy. Unless by telling us that you're serious, you actually MEANT that you were seriously sloppy. Here's a novel idea: how about you just comply with the code?

And brudgers, since you're all serious and stuff about exactly what the code says and how it says it, what section of the "EIBC" addresses lead paint?

I've never met a person who tried to obfuscate by justifying one code solution because of a separate nonexistant code requirement to be terribly reliable in other endeavors. Translated, brudgers, I wouldn't personally loan you a down payment on your errors and omissions insurance.

 

[jim baird]

Re: Smaller egress windows in retrofit

zzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzz

 

[Lou Marks]

Re: Smaller egress windows in retrofit

How many of us have actually done IEBC performance calculation. There are many factors in using the code, be it IBC, IEBC or any other. To answer a single question without the benefit of a complete set of drawing is like quoting a verse out of the bible and getting a group to agree on it meaning. I am sure CA has a means to interpretate the code section as does Viriginia or the ICC.

It is impossible to get agreement without all the facts. I do digital review and will be glad to do a complete review base on IEBC which is the only code that would allow this to occur in egress / rescue openings here required. "My opinion is that the width reduction is more than offset by requiring removal sashes and doubling the height is and increase / equal tradeoff".

As Bugs Bunny said "Thats all folks".

 

[Yikes]

Re: Smaller egress windows in retrofit

Sorry for my confusing terminology of "egress window". I just remember the old Steven Wright joke:

"I was born by Caesarean section... but not so you'd notice. It's just that when I leave a house, I go out through the window."

 

[brudgers]

Re: Smaller egress windows in retrofit

And brudgers, since you're all serious and stuff about exactly what the code says and how it says it, what section of the "EIBC" addresses lead paint?

The IEBC doesn't address EE&RO's. That's in the IBC.

IBC 102.4 addresses lead paint.

 

[texasbo]

Re: Smaller egress windows in retrofit

And brudgers, since you're all serious and stuff about exactly what the code says and how it says it, what section of the "EIBC" addresses lead paint?

The IEBC doesn't address EE&RO's. That's in the IBC.

IBC 102.4 addresses lead paint.

I'm terribly sorry for not being more specific in my request; I forget how limited your attention span is. Please point out the specific document in the code that addresses the abatement of lead paint in existing buildings. You know, the one you used as leverage in the hypothetical brokering of a slipshod code deal to allow a life safety violation to be exacerbated.

 

[brudgers]

Re: Smaller egress windows in retrofit

You are capable of reading the code for yourself, aren't you?

Just take your big shoes off the desk, and open the book.

 

[texasbo]

Re: Smaller egress windows in retrofit

I'm capable of knowing that you're all over the place, and seldom is that place anywhere near a code.

 

[fatboy]

Re: Smaller egress windows in retrofit

Gentlemen.......move on.

 

[texas transplant]

Re: Smaller egress windows in retrofit

As Fatboy said gentlemen,

Move on or LOCK!