Under 50 occupants second exit requirement

[brr]

Portland, OR

I’m attempting to figure out egress for a new café/donut shop going into an existing cafe's space. The occupancy works out to 48 people with A-2 occupancy in the dining area and Business in service areas and in the kitchen.

Non-sprinklered, VB construction. There is currently only one exit with signage at FOH (front of house) and we want to see if we can keep it that way.

I talked with a plans examiner for the City today in an attempt to figure out how to overcome our not having the one-half the diagonal dimension of the space between two exits. We were very close and could make it if we could measure from farthest door frame to frame, but the plans examiner said no – center of door only.

He said that because the BOH had its own exit, we could measure the FOH only for the half-diagonal distance (see second plan image below).

After our video conference was over (scheduling is 3 to 4 business days out for questions), it occurred to me that I should have asked if the FOH could be considered a separate space for determining the common path of egress – across the whole building it’s 86’, with a minimum of 75’ for one exit.

Does the open connection between the BOH and FOH prevent considering the spaces separately, and would that allow just one exit FOH?

 

[Yikes]

I don’t understand why you need 2 exits at all. You said your occupant count for the entire space is 48, and it doesn’t appear that your CPET exceeds 75 feet. So if you only need one exit, why are you concerned about 2 exits and their separation?

 

[walker.t]

We were very close and could make it if we could measure from farthest door frame to frame, but the plans examiner said no – center of door only.

Not sure what your code is in Portland, but you can measure to any point along a door, not just the center:

2021 IBC 1007.1.1.1 Measurement Point (partial quote, emphasis added)
The separation distance required in Section 1007.1.1 shall be measured in accordance with the following:
1. The separation distance to exit or exit access doorways shall be measured to any point along the width of the doorway.

 

[brr]

I don’t understand why you need 2 exits at all. You said your occupant count for the entire space is 48, and it doesn’t appear that your CPET exceeds 75 feet. So if you only need one exit, why are you concerned about 2 exits and their separation?

I assumed that both the front of house and back of house would be considered one space - if that's the case, then the longest common path for one exit is 86'. You can't exit through a kitchen, so it can't be the second exit, and if the 86' requires two exits, then the FOH second exit is required. What I'm wondering is can the BOH stand alone so you can consider each space separately?

 

[steveray]

You need 2….

 

[Yikes]

Thought experiment:
If there was a door between the kitchen BOH and the the cafe FOH, and each has its own separate exit door, then each would be evaluated separately for its own CPET, and each would be less than 75’, so it would comply to treat them separately.
Now imagine that door propped open all the time, which is OK because there’s no required occupancy separation between the kitchen and dining area.
OK, there’s no functional difference between a door propped open all the time v.s just having a cased opening like you’ve already shown.

So IMO it’s ok to treat the two spaces separately, even with the open connection (no door)

 

[Yankee Chronicler]

How did the plans examiner let that toilet room pass? The lavatory occupies the approach clear space for the door.

I can't tell which line represents exit access travel distance and which line represents common path of exit access travel. For both, if you're pushing the limit be sure to measure as favorably to yourself as possible. Note that in the 2021 IBC Commentary, Figure 1017.3(1) shows radiused turns, not sharp right angle turns. I thought that was discussed in the Commentary, but it's not. However, if I remember correctly, it is discussed explicitly in the NFPA 101 Life safety Code. If the minimum required width of the means of egress is 44 inches, draw your lines 22 inches off walls, and round the corners with a 22-inch radius, maintaining 12 inches of clearance from the walls as you round corners.. Maybe because I have always coordinated plan reviews with my fire marshal's office, as far as I'm concerned if it's good enough for NFPA 101, it's good enough for me.

 

[Yankee Chronicler]

It took a while, but I was finally able to download a newer copy of the NFPA 101 Handbook. It no longer includes the figure shown above, but the new figure still shows radiused turns in paths of egress travel. And the language about curving around obstructions with a 12-inch clearance remains.

If anyone is interested in downloading the 2018 NFPA 101 Handbook for reference, the link to the site where I found it is https://annas-archive.org/md5/b26e1533172b5eaff7cf9e87f7fe68c8

I wasn't familiar with that site, so I did some research before I downloaded, and what I found suggested that it's safe. And I scanned the PDF with my anti-virus program after downloading, and it came up clean. Nonetheless, something in my system flagged the site as possibly harboring malware when I started the download, so do your own due diligence.

 

[brr]

It took a while, but I was finally able to download a newer copy of the NFPA 101 Handbook. It no longer includes the figure shown above, but the new figure still sows radiused turns in paths of egress travel. And the language about curving around obstructions with a 12-inch clearance remains.

If anyone is interested in downloading the 2018 NFPA 101 Handbook for reference, the link to the site where I found it is https://annas-archive.org/md5/b26e1533172b5eaff7cf9e87f7fe68c8

I wasn't familiar with that site, so I did some research before I downloaded, and what I found suggested that it's safe. And I scanned the PDF with my anti-virus program after downloading, and it came up clean. Nonetheless, something in my system flagged the site as possibly harboring malware when I started the download, so do your own due diligence.

Thanks Yankee - that radius is the kind of small detail that can make a difference in some situations. It's always emphasised that you must assume obstructions (furniture, etc.) in most situations, so you square off the path, but from now on I'll at least follow your suggestion and radius the corners half the path width.

However, in this situation, the difference is between the 75' limit and 86' feet to the farthest point.

 

[brr]

How did the plans examiner let that toilet room pass? The lavatory occupies the approach clear space for the door.

I appreciate you pointing that out.

We have not submitted yet. I've had to deal with existing restrooms with many bad layout and tight spaces over the years, and I'm still surprised sometimes that local inspectors permit retention of egregious ADA non-compliant restrooms - what I worry about for my clients and myself is someone bringing an ADA lawsuit.

The clearance issue was noted by us. We decided to submit as is. We are upgrading the sink, toilet, and adding grab bars to the side of the toilet - currently only has a grab bar along the back.

What I've advised my client, in writing, is that the door at minimum should be reversed for outswing. However, with an interior lockable door, you still need 12".

We thought a possible remedy would be the outswing door and have a number-key exterior lock and a push-release inside latch. Don't even know if someone makes that type of latch. My client does not want to pay for either a new/reversed door or a new latch.

 

[Yikes]

What I've advised my client, in writing, is that the door at minimum should be reversed for outswing. However, with an interior lockable door, you still need 12".

You only need 12" on the push side of an outswinging door if it is equipped with both a latch and a closer. Of course you will need a latch, but you don't need a closer. If you want the door to close, but don't want a closer, you can install spring hinges. The US Access Board has determined that spring hinges are not considered "closers" for the purpose of this issue.
If you need adjustable speed spring hinges, there's a brand called Waterson; they're not cheap, but they work well.

We thought a possible remedy would be the outswing door and have a number-key exterior lock and a push-release inside latch. Don't even know if someone makes that type of latch. My client does not want to pay for either a new/reversed door or a new latch.

See this hardware recommendation from a discussion last month: https://www.thebuildingcodeforum.co...additional-privacy-features.38732/post-307863

 

[Yankee Chronicler]

Thanks Yankee - that radius is the kind of small detail that can make a difference in some situations. It's always emphasised that you must assume obstructions (furniture, etc.) in most situations, so you square off the path, but from now on I'll at least follow your suggestion and radius the corners half the path width.

However, in this situation, the difference is between the 75' limit and 86' feet to the farthest point.

Where do you consider the most remote point to be? Your diagram isn't clear on that.

 

[brr]

Where do you consider the most remote point to be? Your diagram isn't clear on that.

That's the question. We do not know whether both front and back of house are one space, or whether the FOH is considered separate from the back for purposes of determining egress requirements.

 

[steveray]

You have to look at 1006.2 and 1006.3… you need 2. If you lost the one in the back it would be >75’ to the front it appears.

 

[Yankee Chronicler]

That's the question. We do not know whether both front and back of house are one space, or whether the FOH is considered separate from the back for purposes of determining egress requirements.

You're missing the point. Whether or not the two rooms are one space only applies to measuring the maximum diagonal. The most remote point is the point or points farthest from AN exit. Each of your rooms -- FOH and BOH -- has access to two means of egress doors, irrespective of whether those two doors are "remote."

Both of your dotted lines -- and they aren't identified as to which represents common path of travel and which represents maximum travel distance -- seem to just meander through the space. The dashed line extends from the kitchen exit to the front exit, passing right by the side exit in the FOH space. The phantom line that starts in the utility closet likewise passes right by the side exit door on its way to the front exit door, and it's not the shortest route.

The common path of egress travel is defined in the IBC as:

[BE] Common Path of Egress Travel
That portion of exit access travel distance measured from the most remote point of each room, area or space to that point where the occupants have separate and distinct access to two exits or exit access doorways.

Take the phantom line from the utility closet: I think the path I sketched in red is a shorter route to the front exit door, but why go to the front door at all? BOTH of you lines pass right by the side exit in the FOH space. That door doesn't cease to exist just because it's a few feet too close to the front to be considered "remote." It's still a door and people can still use it to get out of the building. If you only have 49 occupants, you don't need two remote exits, but that doesn't mean you can't have two exits. It just means you don't have two remote exits. If you can reach any one of the exit doors without exceeding the allowable common path of travel limitation -- you're done.

On your diagram, I see a note that the FOH common path of travel is 73 feet and the combined common path of travel is 86 feet. Where are those measured from? If you don't have two REMOTE means of egress -- how are you measuring that? Neither of your lines shows a common path of travel. One of them starts at a remote point, the other connects two exit doors. Neither ends at a point where the occupant has a choice of two paths of egress travel.

You are allowed up to 75 feet common path of exist access travel. If from every point you can get to an exit door in less than 75 feet -- you don't have to worry about common path.

 

[jar546]

OK, other than the accessibility drift, to me, the fact that the occupant load is less than 50 means you only need one exit, providing the travel distance does not exceed 75'. You actually have four exits, and at no point are you greater than 75' from an exit. I don't see an issue here. Yes, I understand that you can't exit through the kitchen unless you are in the kitchen, but even so, those in the public area still have a choice of two exits.

 

[Yankee Chronicler]

OK, other than the accessibility drift, to me, the fact that the occupant load is less than 50 means you only need one exit, providing the travel distance does not exceed 75'. You actually have four exits, and at no point are you greater than 75' from an exit. I don't see an issue here. Yes, I understand that you can't exit through the kitchen unless you are in the kitchen, but even so, those in the public area still have a choice of two exits.

As usual, my comments were more verbose, but we're saying the same thing.

 

[brr]

You're missing the point. Whether or not the two rooms are one space only applies to measuring the maximum diagonal. The most remote point is the point or points farthest from AN exit. Each of your rooms -- FOH and BOH -- has access to two means of egress doors, irrespective of whether those two doors are "remote."

What's causing this whole thing is the usual situation: my client does does not want to have the second front of house door be an exit - it currently isn't signed or labeled in any way from the last tenant's identical use and the last building permit was from the early 1980s, and all plan's on file from the 80s change of use do not even address exiting. There is an exit sign over the front door, which isn't even required in any scenario if the main entry is obvious - Portland Fire Code 1013.1.2. The primary reason for not wanting the second exit is that they want to limit the number of operable entrances when one person is working alone. The secondary reason is that they don't want to have to pay for an exit sign or have an outswing door with panic hardware (which would solve the side door locking problem - and then it would be swinging over the public sidewalk) - the costs may seem trivial, but in my world owners are almost always shaving pennies.

I'd rather be able to tell my client definitively that he must have a second FOH exit, rather than submit and find out differently - a bit of pride protection on my part, but also, I want to thoroughly understand the situation myself.

I'm submitting tomorrow. I have a scheduled conference with a plans examiner on Thursday, so I'll start the conversation with this question and more information, and maybe we won't run out of time like at my 15 minute Friday meeting (he gave me 22 minutes, but spent at least a minute of the meeting time reminding me he was doing me a favor). I'll post a follow up with what the plans examiner says on Thursday. If I were to include the second FOH exit on the permit submittal, I may never know if it's actually required - nothing wrong with redundancy from the AHJ point of view.

 

[steveray]

You shouldn’t need the second front….

 

[Yankee Chronicler]

What's causing this whole thing is the usual situation: my client does does not want to have the second front of house door be an exit - it currently isn't signed or labeled in any way from the last tenant's identical use and the last building permit was from the early 1980s, and all plan's on file from the 80s change of use do not even address exiting. There is an exit sign over the front door, which isn't even required in any scenario if the main entry is obvious - Portland Fire Code 1013.1.2. The primary reason for not wanting the second exit is that they want to limit the number of operable entrances when one person is working alone. The secondary reason is that they don't want to have to pay for an exit sign or have an outswing door with panic hardware (which would solve the side door locking problem - and then it would be swinging over the public sidewalk) - the costs may seem trivial, but in my world owners are almost always shaving pennies.

This is a silly argument. Sorry to be blunt, but it is. If the occupant load is under 50, an exit door doesn't have to swing in the direction of travel. And it can be locked from the outside 24/7/365 -- it just has to be operable from the inside. (In other words, it can be an exit but not an entrance.) If someone who is opening a new business can't afford an exit sign, they should probably re-think opening the business.

Also, what's the locking and latching hardware on door A? Does the owner intend for all the exterior doors to be locked with an employee or employees inside before opening and after closing? If so, take a hard look at IBC 1010.2, 1010.2.1, and 1010.2.2. If the lock is a conventional deadbolt with either a standard thumbturn or a key cylinder on the inside -- it doesn't comply with IBC 1010.2 et seq.

I'd rather be able to tell my client definitively that he must have a second FOH exit, rather than submit and find out differently - a bit of pride protection on my part, but also, I want to thoroughly understand the situation myself.

I'm submitting tomorrow. I have a scheduled conference with a plans examiner on Thursday, so I'll start the conversation with this question and more information, and maybe we won't run out of time like at my 15 minute Friday meeting (he gave me 22 minutes, but spent at least a minute of the meeting time reminding me he was doing me a favor). I'll post a follow up with what the plans examiner says on Thursday. If I were to include the second FOH exit on the permit submittal, I may never know if it's actually required - nothing wrong with redundancy from the AHJ point of view.

Clean up your egress diagram. Steveray thinks you don't need the second FOH door. To not need it, you have to be able to get from any point in the FOH space to door A in 75 feet or less. Your egress diagram doesn't show ANY "most remote point," and doesn't show ANY travel distance from anywhere. You have two lines marked common path of travel, without showing where either route diverges to lead to separate exits.

 

[brr]

Clean up your egress diagram. Steveray thinks you don't need the second FOH door. To not need it, you have to be able to get from any point in the FOH space to door A in 75 feet or less. Your egress diagram doesn't show ANY "most remote point," and doesn't show ANY travel distance from anywhere. You have two lines marked common path of travel, without showing where either route diverges to lead to separate exits.

I think I'm confusing common path with travel distance. The front door is the exit discharge, so, with no non-accessory intervening rooms, you measure directly to the farthest point for travel distance? In this case, that would mean 200'. Is that how my thinking is off?

 

[Yankee Chronicler]

How can the exit access travel distance be 200 feet when the diagonal of the space is only 47'-5"?

Common path of travel (Portland Building Code):



Even if you ignore the side exit, I don't see how the path you show from the utility closet to the front exit can possibly be 200 feet. And I still don't think the path you show is the shortest path.

If you only have one exit, exit access travel distance and common path are the same. But you don't have only one exit -- you have two.

 

[Yankee Chronicler]

These measurements are approximate. I printed a copy, measured the diagonals with an engineer's scale, came up with the ratio, and then applied that to all the other measurements taken off with the engineer's scale.

 

[steveray]

I think I'm confusing common path with travel distance. The front door is the exit discharge, so, with no non-accessory intervening rooms, you measure directly to the farthest point for travel distance? In this case, that would mean 200'. Is that how my thinking is off?

200 is total to any exit… 75 is choice of 2 ways to go. Your blue line might work but the red line around the counter is too long by the blue numbers…