Unenclosed Two-Story Stairways in NFPA 101

[RLGA]

I am not as familiar with NFPA 101 as I am with the IBC, and I am now faced with a project that requires compliance with NFPA 101 (2021 edition).

The project is a two-story office building and per the IBC (2021 edition), two-story stairways are permitted to be unenclosed provided the travel distances from the second story to an exit on the level of exit discharge is within the 300-foot limitation (the building is sprinklered throughout). However, I cannot find a similar provision within NFPA 101.

Section 38.2.4.1 requires "Not less than two separate exits shall be provided on every story." However, there are provisions that permit single exits or single means of egress from a room, area, or story:

Section 38.2.4.6 allows a single means of egress for a two-story building but includes a 100-foot travel distance limitation from any point to the exit discharge. Notice that it states "means of egress" and not "exit." This is considered an "exit access stairway" as mentioned by Section 38.3.1.1(4). There is no provision for two "means of egress" or two exit access stairways from a two-story building.​

Section 38.2.4.3 allows a single exit, provided the travel distance is limited to 100 feet (including within the stairs) and that the stairs are no more than 15 feet in vertical height.​

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However, there are no provisions that address an intermediate condition where one means of egress (i.e., exit access stair) and one exit stair are provided. It seems like it is either two exits, one exit, or one means of egress -- no middle-of-the-road provision.

Also, I should point out that NFPA 101 does not have a definition of an exit access stairway as the IBC does, nor do they describe an exit access stairway anywhere other than in Section 38.3.1.1(4). NFPA 101 does allow "convenience openings" per Section 8.6.9 but states "Such openings shall not serve as a required means of egress," which I interpret as no exit access stairs are permitted.

Has anybody come across this situation before? If so, how was it handled or accepted?

 

[Yankee Chronicler]

NFPA 101-2021:

7.6.3*​

Where open stairways or ramps are permitted as a path of travel to required exits, the distance shall include the travel on the stairway or ramp and the travel from the end of the stairway or ramp to an outside door or other exit in addition to the distance traveled to reach the stairway or ramp.

"Where permitted." This is the way NFPA 101 is organized -- most requirements are occupancy-oriented. That means that open stairs (what we call exit access stairs under the IBC) may be allowed in certain occupancies but not in others. This is supported by other sections within chapter 7:

7.2.2.1.1. Stairs used as a component in the means of egress shall conform to the general requirements of Section 7.1 and to the special requirements of 7.2.2, unless otherwise specified in 7.2.2.1.2.

7.4.1.1. The number of means of egress from any balcony, mezzanine, story, or portion thereof shall be not less than two, except under one of the following conditions:

(1) A single means of egress shall be permitted where permitted in Chapters 11 through 43.
(2) A single means of egress shall be permitted for a mezzanine or balcony where the common path of travel limitations of Chapters 11 through 43 are met.

If the only stairs allowed were enclosed exit stairs, chapter 7 wouldn't refer to "stairs used as a component in the means of egress." So you need to scrutinize the chapter pertaining to your occupancy to see if that chapter allows open stairs in accordance with chapter 7 as a component in the means of egress. Look at 38.2.1.xxx and 38.2.2.xxx. My state doesn't use NFPA 101 for new construction, so I can't access the current edition for new business occupancies.

 

[RLGA]

NFPA 101-2021:

"Where permitted." This is the way NFPA 101 is organized -- most requirements are occupancy-oriented. That means that open stairs (what we call exit access stairs under the IBC) may be allowed in certain occupancies but not in others. This is supported by other sections within chapter 7:

If the only stairs allowed were enclosed exit stairs, chapter 7 wouldn't refer to "stairs used as a component in the means of egress." So you need to scrutinize the chapter pertaining to your occupancy to see if that chapter allows open stairs in accordance with chapter 7 as a component in the means of egress. Look at 38.2.1.xxx and 38.2.2.xxx. My state doesn't use NFPA 101 for new construction, so I can't access the current edition for new business occupancies.

I understand NFPA 101 is occupancy-driven, so I started in Chapter 38 (new business occupancies). However, nowhere does it state in Chapter 38 open stairways and ramps are permitted or not permitted; thus, I assumed by Chapter 38's lack of a reference to Section 7.6.3, open stairways are not permitted.

 

[Yankee Chronicler]

And I take it from the sections of chapter 7 that I quoted above that open stairs ARE allowed. Instead of calling them "exit access stairs" they are included under the term "means of egress component."

Unfortunately, my NFPA 101 Handbook is at the office, so I don't have access to any explanatory material at the moment.

 

[RLGA]

And I take it from the sections of chapter 7 that I quoted above that open stairs ARE allowed. Instead of calling them "exit access stairs" they are included under the term "means of egress component."

Unfortunately, my NFPA 101 Handbook is at the office, so I don't have access to any explanatory material at the moment.

Sounds hopeful, but what about Section 7.2.2.5.1.1?

"All inside stairs serving as an exit or exit component shall be enclosed in accordance with 7.1.3.2."​

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Using the term "exit" is straightforward, since a definition exists for that term, and an exit access stairway would not be considered an exit. However, the use of the words "exit component" is not clear, and has no definition. Is an exit access stairway considered an "exit component"? An exit access stairway is definitely a "means of egress" component, but that is not the term they used. If an "exit component" is meant to include only those items that are part of an "exit," then your statement above may be true.

Assuming "exit or exit component" is strictly meant to apply to exits, then Section 7.2.2.5.1.2 would apply to exit access stairs; thus, sending us to Section 8.6 for vertical openings. The only part of this section that would apply is Section 8.6.9 for "Convenience Openings," as I previously mentioned. I can have a stair in a convenience opening, but I cannot use it as a means of egress per Sections 8.6.9.1(6) and 8.6.9.2(1).

However, for new business occupancies, Section 38.3.1.1(4) states "Exit access stairs in accordnace with 38.2.4.6 shall be permitted to be unenclosed." This leads us back to the provision that allows a "single means of egress" stairway that I mentioned in my original post--not multiple unenclosed stairs. This may be the "where permitted" comes into play. Thus, if I have two unenclosed stairs, one stair would have to act as the only means of egress (i.e., a single means of egress stair per Section 38.2.4.6 which severely limits travel distance), and the other stair is the "convenience stair."

In my opinion, there is no clear path in NFPA 101 that allows multiple two-story unenclosed stairs to be used as multiple means of egress.

 

[Yankee Chronicler]

Sounds hopeful, but what about Section 7.2.2.5.1.1?

"All inside stairs serving as an exit or exit component shall be enclosed in accordance with 7.1.3.2."​

But 7.1.3.2 specifically requires enclosure for "exits," and doesn't even mention "exit components." Therefore, I would read 7.2.2.5.1.1 as requiring that "exits" must be enclosed, and silent on enclosure of other exit components.

Of course, my opinion doesn't count. What counts is the opinion of whatever AHJ enforces NFPA 101 in the jurisdiction where the project is located.

Do you have access to a copy of the NFPA 101 Handbook? It might provide some guidance. If you can find support in the Handbook, most AHJs are more than willing to accept what the Handbook says as guidance.

 

[RLGA]

But 7.1.3.2 specifically requires enclosure for "exits," and doesn't even mention "exit components." Therefore, I would read 7.2.2.5.1.1 as requiring that "exits" must be enclosed, and silent on enclosure of other exit components.

Of course, my opinion doesn't count. What counts is the opinion of whatever AHJ enforces NFPA 101 in the jurisdiction where the project is located.

Do you have access to a copy of the NFPA 101 Handbook? It might provide some guidance. If you can find support in the Handbook, most AHJs are more than willing to accept what the Handbook says as guidance.

Excellent point--I did not pick up on that.

 

[Yankee Chronicler]

Isn't it great that we have codes to clarify all this stuff for us? Otherwise, nobody would know what to do.

 

[RLGA]

As a follow-up, I submitted the question to NFPA's Technical Question service. Here is the response I received:

"An open or partially enclosed stair might be permitted to serve as means of egress; however, such a stair is not an exit, which must be fully enclosed on all levels (see 7.1.3.2 and 7.2.2.5.1). In new business occupancies, at least two exits (e.g., fully enclosed stairs) must be provided on every story in accordance with 38.2.4.1 unless one of the single-exit exemptions of 38.2.4.3 through 38.2.4.6 is met. In the arrangement you describe, it appears that no exits are provided on the second story, which is not permitted."​

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So, yes, a building may have unenclosed two-story stairways as a means of egress, but it must still have two enclosed exits—another draconian requirement from the NFPA.

 

[steveray]

As a follow-up, I submitted the question to NFPA's Technical Question service. Here is the response I received:

"An open or partially enclosed stair might be permitted to serve as means of egress; however, such a stair is not an exit, which must be fully enclosed on all levels (see 7.1.3.2 and 7.2.2.5.1). In new business occupancies, at least two exits (e.g., fully enclosed stairs) must be provided on every story in accordance with 38.2.4.1 unless one of the single-exit exemptions of 38.2.4.3 through 38.2.4.6 is met. In the arrangement you describe, it appears that no exits are provided on the second story, which is not permitted."​

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So, yes, a building may have unenclosed two-story stairways as a means of egress, but it must still have two enclosed exits—another draconian requirement from the NFPA.

Which is why CT hasn't kept up with ICC on exit access stairs and limit them to 10 people to keep the fire folks sorta happy....

1019.3 Occupancies Other Than Groups I-2 and I-3​

In other than Group I-2 and I-3 occupancies, floor openings containing exit access stairways or ramps that do not comply with one of the conditions listed in this section shall be enclosed with a shaft enclosure constructed in accordance with Section 713.

1. In buildings equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1 with other than Group H or I occupancies, exit access stairways and ramps serving an occupant load of less than 10 not more than one story above the level of exit discharge.

 

[Yankee Chronicler]

As a follow-up, I submitted the question to NFPA's Technical Question service. Here is the response I received:

"An open or partially enclosed stair might be permitted to serve as means of egress; however, such a stair is not an exit, which must be fully enclosed on all levels (see 7.1.3.2 and 7.2.2.5.1). In new business occupancies, at least two exits (e.g., fully enclosed stairs) must be provided on every story in accordance with 38.2.4.1 unless one of the single-exit exemptions of 38.2.4.3 through 38.2.4.6 is met. In the arrangement you describe, it appears that no exits are provided on the second story, which is not permitted."​

​

So, yes, a building may have unenclosed two-story stairways as a means of egress, but it must still have two enclosed exits—another draconian requirement from the NFPA.

But the NFPA opinion acknowledges that under certain conditions, only one stair needs to be an "exit" and enclosed. You have to meet one of the exceptions listed in 38.2.4.3 through 38.2.4.6.

I'm too rushed to check this out, but it sounds like it's not too different from the IBC conditions that allow for an unenclosed exit access stair.

 

[RLGA]

But the NFPA opinion acknowledges that under certain conditions, only one stair needs to be an "exit" and enclosed. You have to meet one of the exceptions listed in 38.2.4.3 through 38.2.4.6.

I'm too rushed to check this out, but it sounds like it's not too different from the IBC conditions that allow for an unenclosed exit access stair.

Yes, 100 occupants (no problem) and 100-foot total travel distance including travel in the exit (problem). That last part, in my opinion, is overly restrictive.

If two exits are provided, NFPA 101 permits a 300-foot travel distance to any exit when a sprinkler system is provided. But, if you cut the number of exits to one, you are limited to a 100-foot travel distance to the exit discharge. If you have stairs at the maximum height permitted by 38.2.4.3 (15 feet), that will leave you roughly 65 feet of travel distance on the second story.

So, with two exits, you could have somewhere around a 180,000 sq. ft. story with a 300-foot travel distance (depending on where the stairs are situated), compared to a 1,060 sq. ft. story with a single exit and a 65-foot travel distance to the exit.

As I said in my previous post, this is draconian and very much not mainstream office building design. The NFPA 101 treats small- to moderate-sized office buildings like large corporate centers.

 

[Tim Mailloux]

Which is why CT hasn't kept up with ICC on exit access stairs and limit them to 10 people to keep the fire folks sorta happy....

1019.3 Occupancies Other Than Groups I-2 and I-3​

In other than Group I-2 and I-3 occupancies, floor openings containing exit access stairways or ramps that do not comply with one of the conditions listed in this section shall be enclosed with a shaft enclosure constructed in accordance with Section 713.

1. In buildings equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1 with other than Group H or I occupancies, exit access stairways and ramps serving an occupant load of less than 10 not more than one story above the level of exit discharge.

hopefully once all the old guard fire CT marshals retire we can move on from the NFPA remnants we add into the CT Building code. The fact that we still have to calculate stairs at .3" per person even with sprinklers is a real killer on many of my renovation projects.

 

[steveray]

hopefully once all the old guard fire CT marshals retire we can move on from the NFPA remnants we add into the CT Building code. The fact that we still have to calculate stairs at .3" per person even with sprinklers is a real killer on many of my renovation projects.

Not to go OT, but they filed a bill today to take themselves out of DAS....You should propose that to the IEBC for an amendment....Or maybe unamendment...Leave it for new and they might let it in......And I kinda agree....

 

[Tim Mailloux]

Not to go OT, but they filed a bill today to take themselves out of DAS....You should propose that to the IEBC for an amendment....Or maybe unamendment...Leave it for new and they might let it in......And I kinda agree....

I tied all that last code cycle and it got smacked down hard!